Qualitative Online Feedback: Supply Chain Disclosure - Global ...

G4 DEVELOPMENT 

Second G4 Public Comment Period: Submissions 

Document 8 of 12 – Qualitative Online 

Feedback: Supply Chain Disclosure 

February 2013

INTRODUCTION 

ABOUT THE SUBMISSIONS DOCUMENTS 

In 2010 GRI began the development of the fourth generation of its Sustainability Reporting 

Guidelines, G4. 

Following GRI’s Due Process 1 , this development includes the use of Public Comment Periods (PCPs) to 

gather stakeholder feedback on proposed updates. 

The series of Submissions documents presents the submissions received during the second G4 Public 

Comment Period on the G4 Exposure Draft, and the Additional Public Comment Period for G4 

Thematic Revisions. These PCPs were held for a period of 90 days each, between June and November 

2012. 

The documents include a list of the individuals and organizations that submitted feedback, the 

verbatim contents of all online and offline feedback submissions, and notes and summaries of the 

G4-related Workshops. 

All submissions are reproduced in these documents exactly as received by GRI, with no alterations. 

To protect personal data, personal contact details (e.g., email addresses, telephone numbers) have 

been removed. 

Submissions received in languages other than English were professionally translated and analyzed in 

English. In these documents, these submissions are presented in their original language. 

There are 12 documents, each available for download as a standalone file on the GRI website. The 

table below gives an overview of the contents of each document. 

1 

Process based on principles according to which all GRI Guidelines documents must be developed 


Introduction 

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Documents Contents Page 

Second G4 Public Comment Period 

1: List of 

Participants 

A list of the individuals and organizations that submitted feedback. 12 

2: Statistics: 

Quantitative 

Online Feedback 

3-8: Qualitative 

Online Feedback 

9: Offline 

Feedback 

10: Workshop 

Summaries 

11: Anticorruption 

12: Greenhouse 

Gas (GHG) 

Emissions 

Detailed statistics about the answers to survey questions posed on 

the online GRI Consultation Platform. 

These documents contain all the verbatim comments received 86 

through the GRI Consultation Platform for each of the following areas 

of proposed updates: 

3. General Questions 

4. Application Levels 

5. Boundary 

6. Disclosure on Management Approach 

7. Governance and Remuneration 

8. Supply Chain Disclosure 

All the submissions received via email or letters, presented verbatim. 1613 

Summaries of 49 G4 Workshops held worldwide by GRI. 1918 

Additional Public Comment Period for G4 Thematic Revisions 

This document contains: 

 

 

A list of the individuals and organizations that submitted 

feedback 

Detailed statistics about the submissions received through 

the GRI Consultation Platform 

All the online and offline submissions received for Anticorruption, 

presented verbatim 

This document contains: 

 

 

 

 

A list of individuals and organizations that submitted 

feedback 

Detailed statistics about the submissions received through 

the GRI Consultation Platform 

All the online and offline submissions received for GHG 

Emissions, presented verbatim 

The notes taken at two G4 Workshops on GHG Emissions, 

held in Brazil 

33 

2130 

2275 


Introduction 

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G4 DEVELOPMENT AND G4 OBJECTIVES 

In September 2010, GRI’s Board of Directors approved plans to start developing the next generation 

of its reporting Guidelines (G4), and set out the following objectives: 

• to offer guidance in a user-friendly way, so that new reporters can easily understand and use 

the Guidelines 

• to improve the technical quality of the Guidelines’ content in order to eliminate ambiguities 

and differing interpretations – for the benefit of reporters and information users alike 

• to harmonize as much as possible with other internationally accepted standards 

• to improve guidance on identifying ‘material’ issues – from different stakeholders’ perspective 

– to be included in the sustainability reports 

• to offer guidance on how to link the sustainability reporting process to the preparation of an 

Integrated Report aligned with the guidance to be developed by the International Integrated 

Reporting Council (IIRC) 

In May 2011, GRI began informal external consultations, to understand what was considered to be 

needed in order to achieve the objectives stated above. The GRI Guidelines’ development must 

follow a Due Process, which ensures that all efforts are made to involve and consider the interests of 

all of GRI’s stakeholders (including, but not limited to businesses, civil society organizations, financial 

markets, consultancy services, labor representatives and academics). 

GRI launched Primer Surveys for Organizational Stakeholders, reporters and other groups to gather 

views on G4’s potential structure and content. Alongside this, a public ‘Call for sustainability 

reporting topics’ was held in May and June 2011 to collect input on which new issues should be 

covered in G4. Results of this consultation were included in the Survey of the first Public Comment 

Period (PCP) for G4. GRI also asked individuals and organizations to register their interest in taking 

part in the first G4 Public Comment Period. This step helped ensure that the views of a regionally 

balanced and diverse group of stakeholders were taken into account. 

The first G4 PCP, which ran from August to November 2011, was the start of the formal consultation 

process. It attracted around 2300 participants, 1832 of whom provided a submission via an online 

survey. The results of the first G4 PCP can be found on the GRI website. 

Based on the G4 objectives set by the Board of Directors, the results of this first consultation and 

previous informal consultations, the following Working Groups were created to develop revised 

content for the Guidelines: 

• Application Levels 

• Boundary 

• Disclosure on Management Approach 

• Governance and Remuneration 

• Supply Chain Disclosure 

• Anti-corruption 

• Greenhouse Gas (GHG) Emissions 


Introduction 

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As defined in the GRI Due Process, Working Groups are formed by the Secretariat, under the 

direction of the Board of Directors and consultation with the Technical Advisory Committee 2 . 

Selection criteria include expertise, stakeholder diversity, and availability. Proposed revisions to the 

text of the Guidelines or Protocols are drafted by the Working Groups as outlined under overarching 

Due Process principles. The Technical Advisory Committee is responsible for reviewing proposals put 

forth by the Working Groups. 

On 25 June 2012, GRI launched the second G4 Public Comment Period, which sought the public’s 

feedback on an Exposure Draft of G4. The draft featured significant proposed changes to content for 

Application Levels, Boundary, Disclosure on Management Approach, Governance, and Supply Chain 

Disclosure. The document was available for comment from 25 June to 25 September 2012. 

On 14 August 2012, GRI launched an Additional Public Comment Period for G4 Thematic Revisions. 

This Additional PCP was complementary to the second G4 PCP and invited the public to provide 

feedback on the proposed thematic revisions to the topics of Anti-corruption and Greenhouse Gas 

(GHG) Emissions. The documents were available for comment from 14 August to 12 November 2012. 

The proposed thematic revisions were built upon the content and structure featured in the G4 

Exposure Draft. 

During these PCPs, any interested party could provide feedback on specific proposed revisions to the 

Guidelines. 

The results of the second G4 PCP and the Additional PCP for G4 Thematic Revisions informed the 

work of the GRI Working Groups and Governance Bodies to finalize the G4 Guidelines. 

The G4 Guidelines are planned to be launched in May 2013. 

2 

The Technical Advisory Committee (TAC) provides GRI’s Board and network with high-level, expert advice on reporting, and sustainability. 


Introduction 

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SECOND G4 PUBLIC COMMENT PERIOD 

The second G4 PCP invited the public to provide comments on the G4 Exposure Draft. 

The G4 Exposure Draft represents the combined efforts, under the direction of the Board of Directors 

(which consults the Stakeholder Council 3 ), of the Working Groups, the Secretariat and the Technical 

Advisory Committee. In addition, a Technical Editing Task Force was created to review the content of 

the Guidelines and make recommendations to improve their clarity and enhance the consistency of 

their application. 

The proposed significant changes to the Guidelines presented in the G4 Exposure Draft are 

summarized below. At the core of these changes was a focus on materiality – in combination with 

other reporting principles – in all stages of sustainability reporting, from the identification of the 

content and boundaries of the report, to the disclosures provided by the organization. 

APPLICATION LEVELS 

The Application Levels were introduced with the launch of the G3 Guidelines to assist organizations 

in communicating the degree of transparency of their sustainability reports against the Guidelines. 

This system has served organizations well in allowing them the start of a journey, in most cases on 

voluntary basis, in sustainability reporting. In recent years, however, concerns have been expressed 

by different stakeholders that the Application Levels are wrongly understood by some report users to 

be an opinion on the quality of the report, or even a reflection of the sustainability performance of 

the organization. 

To remedy these concerns and, more importantly, to align with other international disclosure 

standards, it was proposed that the Application Levels as they presently exist in the G3 and G3.1 

Guidelines be discontinued. The proposal made in the G4 Exposure Draft was to replace Application 

Levels with criteria that must be met for an organization to claim that the report has been prepared 

‘in accordance with’ G4. In addition, in recognition of the time and effort required to prepare an 

initial sustainability report, transitional provisions were proposed to allow first time reporters, for 

two reporting periods, to incrementally apply G4 by disclosing in the report the required information 

that has been omitted, as well as stating their commitment for the report to be fully in accordance 

with G4 once the transition period is over. 

BOUNDARY 

The process in the existing Technical Protocol Applying the Report Content Principles was revised to 

direct organizations on how to define the content and boundaries of a sustainability report in one 

sequence of process steps, thus to answer the question of what to report. The process began with 

the mapping of a value chain(s) and the identification of relevant topics and boundaries, followed by 

the prioritization of relevant topics as material GRI Aspects, for validation. The outcomes of the 

3 

The Stakeholder Council is GRI’s formal stakeholder policy forum. The Stakeholder Council debates and provides input on key strategic 

and policy issues. 


Introduction 

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process consisted of (1) a map of the organization’s value chain, (2) a list of material Aspects (and 

where the impact occurs within the value chain(s)) and (3) related Standard Disclosures to be 

included in the sustainability report. The Standard Disclosures include the Core Indicators which are 

required to be disclosed by the organization; if a Core Indicator is not disclosed, the organization is 

required to explain the reasons why it is not provided. 

DISCLOSURE ON MANAGEMENT APPROACH 

The Disclosures on Management Approach are intended to provide organizations with an 

opportunity to explain how they are managing material economic, environmental, and social 

impacts. The G4 Exposure Draft outlined a generic approach for all topics and proposed that the 

Disclosures on Management Approach should be provided at the Aspect level to reflect management 

practices. However, when a topic is managed at a different level, the Disclosures on Management 

Approach should be reported at that level. That level may be general (applicable to Categories), or 

more detailed (applicable to Aspects or an organization’s self-defined topics), or specific (applicable 

to Indicators). 

GOVERNANCE AND REMUNERATION 

The G4 Exposure Draft proposed a number of changes to governance and remuneration disclosures 

to strengthen the link between governance and sustainability performance, taking into account the 

consistency within existing governance frameworks and developments in that field. The proposed 

changes included new disclosures in the Profile section of the report on the ratio of executive 

compensation to median compensation, the ratio of executive compensation to lowest 

compensation and the ratio of executive compensation increase to median compensation. 

SUPPLY CHAIN DISCLOSURE 

New and amended disclosures on the supply chain were included in the G4 Exposure Draft. They 

included a new definition of supply chain and of supplier, as well as new disclosures on the supply 

chain, including procurement practices, screening and assessment as well as remediation. In 

addition, guidance was included on how to apply the supply chain reporting requirements. 

STRUCTURE AND FORMAT OF THE G4 GUIDELINES 

Throughout the development of the G4 Exposure Draft, an editorial review was conducted to 

improve the clarity and technical quality of the text as well as to facilitate the implementation of the 

Guidelines. One of the changes was the split of the text in the Indicator Protocols into standard 

disclosures and guidance, to facilitate the identification of the reporting requirements by 

organizations and to offer guidance in a user-friendly way. 

GRI plans to offer the finally approved G4 content through a web-based platform which will present 

other user-friendly features. 


Introduction 

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ADDITIONAL PUBLIC COMMENT PERIOD FOR G4 THEMATIC REVISIONS 

An Additional PCP for G4 Thematic Revisions ran from 14 August to 12 November 2012 and featured 

proposed changes to GRI’s guidance for reporting Anti-corruption and Greenhouse Gas (GHG) 

Emissions. 

The proposed changes to the Guidelines presented in the Thematic Revisions are summarized below. 

ANTI-CORRUPTION 

The Anti-corruption Working Group proposed a number of changes to existing disclosures for anticorruption, 

and proposed to locate certain new and revised disclosures under a new Ethics section. 

Updated definitions and references, and changes to existing terminology, were included to make 

disclosures clearer and more focused; and to align G4 with best practice in anti-corruption disclosure. 

The proposed revisions included: 

 

 

 

Strategy, Profile and Governance 

 

New disclosures under a new section ‘e. Ethics’ 

Disclosure on Management Approach 

 

Indicators 

 

 

New disclosures and guidance (Anti-corruption Aspect, Society Category) 

Specific edits to Indicators SO2, SO3, and SO4 (Anti-corruption Aspect, Society 

Category) 

Specific edits to Indicator SO6 (Public Policy Aspect, Society Category) 

GREENHOUSE GAS (GHG) EMISSIONS 

The GHG Emissions Working Group proposed a number of changes mainly covering disclosures under 

the Aspects of Energy and Emissions (formerly Emissions, Effluents, and Waste) in the Environmental 

Category. 

Disclosures in other areas of the Guidelines relevant to reporting GHG emissions are also included. 

The proposed revisions intended to support reporting and align with the GHG Protocol, jointly 

released by the World Resources Institute and the World Business Council for Sustainable 

Development, and the ISO 14064 standard produced by the International Organisation for 

Standardisation. 

The proposed GHG Emissions Indicators are fully aligned with the GHG Protocol’s grouping of 

emissions into three subsets (Scopes 1, 2, and 3), as well as the ISO 14064 grouping. Energy 

Indicators have been modified to align with the GHG Emissions Indicators for more streamlined 

reporting. Intensity Indicators were added for both energy and GHG emissions. 

Compilation points for each Indicator have been made consistent across Indicators and other 

reporting frameworks, and allow for more detailed reporting to assist with the comparability of data. 


Introduction 

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The proposed revisions included: 

 

 

Disclosure on Management Approach 

New disclosures and guidance for the Energy and Emissions Aspect (Environmental 

Category) 

Indicators 

Edits to Indicator EC2 (Economic Performance Aspect, Economic Category) 

 

 

Edits to Indicators EN3 – EN7 and Indicators EN16 – EN20 (Energy and Emissions 

Aspects, Environmental Category) 

New Indicators under the Energy and Emissions Aspects, Environmental Category 

METHODOLOGY FOR GATHERING FEEDBACK 

During the second G4 PCP and the Additional PCP for G4 Thematic Revisions, GRI invited any 

interested party to submit feedback on the proposed updates. 

GRI gathered feedback on the G4 Exposure Draft and Thematic Revisions through three means: 

 

 

 

The online GRI Consultation Platform, which included general and specific survey questions 

Letters and emails to GRI’s Secretariat 

Workshops held worldwide by GRI 

The online GRI Consultation Platform offered the option of making comments on the presented 

documents using a document review function, and posed survey questions for each PCP: 27 

questions for the G4 Exposure Draft, and seven questions for the Thematic Revisions. 

For the G4 Exposure Draft, both general and specific questions were posed. General questions were 

on structural or overall impressions of the Exposure Draft. Specific questions were on the proposals 

for each content area – Application Levels, Boundary, Disclosure on Management Approach, 

Governance and Remuneration, and Supply Chain Disclosure. 

For the Thematic Revisions, GRI posed seven specific questions on the proposals for Anti-corruption 

and GHG Emissions. 

Three formats were used for the questions: 

 

 

 

Questions with the option of selecting ‘Yes’ and no further comments, or selecting ‘No’ and 

offering comments. Only a ‘No’ response invited the option to provide comments. This 

means that a ‘Yes’ response reflected complete acceptance, while a ‘No’ response may have 

been accompanied by explanations of agreement or disagreement with the question 

Multiple choice questions, with no option to provide comments 

Open-ended questions, designed to invite unguided responses and broader feedback 


Introduction 

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TERMINOLOGY 

The following terminology is used in the series of Submissions documents, and was used for GRI’s 

statistical analysis of the submissions: 

 

 

 

 

Submission: an input of PCP feedback received by GRI through the Consultation Platform, 

letters or emails to GRI’s Secretariat; 

 

 

 

 

 

Online submission: submission received through the Consultation Platform 

Offline submission: submission by letter and/or e-mail to the Secretariat 

Personal submission: submission representing the view of an individual 

Organizational submission: submission representing the view of an organization 

Collective submission: submission representing the views of more than one 

individual and/or organization, with a number of signatories 

Participant: each individual or organization providing PCP feedback with an online or offline 

submission. Collective submissions represent the views of a number of participants 

Quantitative online feedback: detailed statistics about the answers to survey questions 

posed on the online GRI Consultation Platform. 

Qualitative feedback: the verbatim contents of textual submissions 

METHODOLOGY FOR CLASSIFYING SUBMISSIONS 

Document 1 of these documents presents a list of the Second G4 PCP participants, grouped into 

online and offline submissions. 

In some cases, GRI received more than one submission from the same organization or individual. 

GRI’s intention for both PCPs, however, was to permit only one submission from the same 

organization or individual; in the case of the Thematic Revisions, the intention was to permit one 

submission from the same organization or individual on Anti-corruption, and one on Greenhouse Gas 

(GHG) Emissions. 

When more than one submission from the same organization or individual was received, the 

following classification criteria were adopted: 

 

Complementary submissions: if the content of the multiple submissions was complementary, 

the submissions were combined as follows: 

 

 

 

If all complementary submissions were received through the Consultation Platform, 

the combined submission is presented only once in Document 1 (List of Participants), 

Document 2 (Statistics: Quantitative Online Feedback) and Documents 3-8 

(Qualitative Online Feedback). 

If all complementary submissions were received offline, the combined submission is 

presented only once in the offline section of Document 1 (List of Participants) and 

Document 9 (Offline Feedback). 

If the complementary submissions were made through the Consultation Platform 

and offline through letters or emails, GRI combined both submissions and classified 


Introduction 

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them as online or offline, based on the submission which had the most substantive 

content. 

Duplicate submissions: submissions with similar or identical content sent by the same 

organization or individual through both the Consultation Platform and offline through letters 

or emails were only considered once for analysis. 

Conflicting submissions: if the content of the multiple submissions was conflicting, GRI 

contacted the organization or individual to clarify which of the submissions was to be 

considered as either organizational or personal 

GRI received several collective submissions, representing the views of a number of participants. The 

signatories to these collective submissions can be found in Document 1 (List of Participants) under 

the heading ‘Collective Responses’. 

In several instances, participants did not provide their profile information, such as constituency 

group and/or reporting relationship. For data integrity purposes, GRI either contacted the participant 

for clarifications or completed the profile information when it was possible to identify the missing 

data, e.g., through the email domain, organization name, or website. 

GRI staff was not allowed to provide feedback during the PCPs. Feedback received from GRI staff 

members is not included in this summary report and was not considered for analysis. 

A document describing the methodology used by the Secretariat for analyzing the feedback received 

during the second G4 Public Comment Period and the Additional Public Comment Period for G4 

Thematic Revisions is available on the GRI website. 


Introduction 

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8 QUALITATIVE ONLINE FEEDBACK: SUPPLY CHAIN DISCLOSURE 

8.1 ABOUT THIS DOCUMENT 

This is number 8 in the series of 12 Submissions documents. All these documents are available for download as a standalone file on the GRI website. 

This document contains all the verbatim comments received through the GRI Consultation Platform regarding Supply Chain Disclosure. These comments are 

presented exactly as received by GRI, with no alterations. The comments are organized by question and document review. 

8.2 OVERVIEW OF SUBMISSIONS BY QUESTION: SUPPLY CHAIN DISCLOSURE 

Table 94 below provides an overview of the online submissions that provided a response to the Supply Chain Disclosure Questions on the GRI Consultation 

Platform. Percentages in the first column are calculated based on the total 590 online submissions. 

Table 94. Overview of submissions by question: Supply Chain Disclosure 

Questions for General Comment 

% of total 

submissions 

answering this 

question 

% of submissions 

answering 

'Yes‘ and no 

further 

comments 

% of submissions 

offering 

comments 

SC1 – Do you consider the proposed definitions of “supply chain” and “supplier” appropriate and complete? 55% 52% 48% 

SC2 – Do you consider the proposed supply chain-specific Indicators to be effective measures for performance and feasible 

to report? 

56% 29% 71% 

SC3 – Do you consider the proposed disclosures related to supply chain appropriate and/or complete? 54% 36% 64% 

SC4 – Do you consider the proposed guidance provided to support disclosure on supply chain related issues appropriate 

and/or complete? 

52% 51% 49% 

SC5 – Do you consider the proposed supply-chain related references appropriate and complete? 47% 73% 27% 

SC6 – Do you have other general comments related to the Supply Chain Disclosures? 33% - - 


Document 8 of 12 – Qualitative Online Feedback: Supply Chain Disclosure 

Page 1155 of 2491

8.3 QUESTIONS FOR GENERAL COMMENT: SUPPLY CHAIN FEEDBACK 

HOW TO NAVIGATE THIS SECTION 

The GRI Consultation Platform combined an online survey with a document review function, allowing users to respond to questions GRI posed and to 

comment on the proposals for new and revised contents. 

The following section contains the responses to the survey’s questions, received via the GRI Consultation Platform for this particular content area. The 

comments are presented in tables and in alphabetical order. The tables can be read in the following manner: 

Comment Constituency Region Reporting 

Relationship 

Text 

Mediating 

Institution 

Europe 

Reporter 

Consultant 

Assurance 

Provider 

Report Reader 

Other XX 



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SUPPLY CHAIN Q1 

Q1) Do you consider the proposed definitions of “supply chain” and “suppliers” appropriate and complete? 

Yes 

No, please clarify:________________ 

% of total submissions 

answering this question 

55 

% of 

submissions 

answering 


further 

comments 

% of 

submissions 

offering 

comments 

52 48 

ORGANIZATIONAL SUBMISSIONS 


Relationship 

"Supply chain" and "supplier" are understandable, but the inclusion of "value chain" makes things very confusing. Business Northern Reporter 

America 

"Supply chain" is not completely in accordance with classic deffinition, and may lead to missunderstandings. Business Latin America Reporter 

Report Reader 

• The definitions are generally appropriate. 

Business Europe Reporter 

• Wherever feasible, GRI could consider to align the definitions more closely with ISO 26000. 

• The list of suppliers presented in the G4 draft focuses mainly on indirect suppliers, while the majority of direct suppliers like 

manufacturers seems to be missing (see p. 315/line 2681). 

A much clearer definition of supply chain is required. Are you including first tier and/or second tier suppliers? This should be 

worked out in more detail. 

Financial 

Markets & 

Information 

Users 

Europe 

Report Reader 

A) We use the term "supplier" for only a portion of what is included in the definition; specifically we include only those organizations 

that "directly" provide materials or products as "suppliers", which would exclude "consultants", "contractors", "homeworkers", 

"independent contractors", and "subcontractors"; we use the term "subcontractor" for those organizations that provide services to 

us, including "consultants", "contractors", "independent contractors", and "subcontractors", but would exclude "homeworkers"; 

however, for purposes of this reporting we can combine them and refer to them as "suppliers", with the exception of 

"homeworkers" and any company that "indirectly" furnished goods or services to our suppliers or subcontractors. As defined by GRI, 

the supplier definition is quite broad and would be difficult to assess. 

Mediating 

Institution 

Northern 

America 

Reporter 

Consultant 

Assurance 

Provider 

Report Reader 



Page 1157 of 2491


Relationship 

B) The definition of "supply chain" appears acceptable. 

Al principio de la definición en el glosario, falta incorporar Supply Chain . Sólo se deben considerar Supplier directos, ya que agregar 

a los indirectos es un exceso. No se debería juntar a proveedores y contratistas, porque su rol es diferente. 

Although the definition of “supplier” is extremely comprehensive, no guidance is given as to how companies should apply this 

definition if their tracking of supply chain activities defines “suppliers” in other terms. 

We suggest: that the GRI specify instances where it may be appropriate for companies to reshape the definition of “supplier” to 

facilitate more transparent reporting, and how that modification should be communicated. 

As indicated earlier in this questionnaire, we believe organisations that use large numbers of suppliers may need a system for 

rationalising their reporting on them that focuses on their most significant risks. 

As per our comment in the Boundary section. Governments, regulators and the judiciary as suppliers of permits and licences to 

operate may be missing from this list. 

As per our comment in the Boundary section. Governments, regulators and the judiciary as suppliers of permits and licences to 

operate may be missing from this list. 

As per our comment in the Boundary section. Governments, regulators and the judiciary as suppliers of permits and licences 

to operate may be missing from this list. 

Clarity in terminology is required 

The glossary section could refer to the definitions given in ISO documents for certain terminologies used in various areas of the G4 

Guidelines such as sustainability topic, aspect, impact, value chain, supply chain, etc. 

Clarity in terminology is required: The glossary section could refer to the definitions given in ISO documents for certain 

terminologies used in various areas of the G4 Guidelines such as sustainability topic, aspect, impact, value chain, supply chain, etc. 

Business Latin America Reporter 

Mediating 

Institution 

Northern 

America 

Reporter 

Consultant 

Report Reader 

Business Europe Consultant 

Our members 

help 

organisations 

prepare and 

use 

sustainability 

reports 

Financial Europe 

Report Reader 

Markets & 

Information 

Users 

Financial 

Markets & 

Information 

Users 

Financial 

Markets & 

Information 

Users 

Asia 

Europe 

Report Reader 

Data provider 

Report Reader 

Business Asia Reporter 

Report Reader 




Page 1158 of 2491


Relationship 

Clarity in terminology is required: 



Mediating 

Institution 

Asia 

Consultant 

Certified 

Training 

Partner & 

Consultant on 

Sustainability 

Reporting 

Clarity on terminology is required. Business Asia Reporter 

Currently too broadly defined for organizations that use thousands of suppliers. Needs to be narrowed. 

Civil Society Northern Report Reader 

Organization America 

Currently too broadly defined for organizations that use thousands of suppliers. Needs to be narrowed. 



Definition of supplier is very wide - for instance one would not normally distinguish between "contractors" and "independent Business Europe Reporter 

contractors", nor would one consider "homeworkers" in that definition as they are usually employees. 

For the definition "supplier", remove "home workers" from the bulleted definitions of "supplier" since "home workers" are 

employees of a "supplier" and their work location should not be classified separately. 

Business Northern 

America 

Reporter 

Report Reader 

Given the prominence accorded to these two terms it is probably prudent to give a clear, prominent definition of these at the 

beginning of the guidelines 

Mediating 

Institution 

Europe 

Reporter 

Consultant 

Assurance 

Provider 

Report Reader 

Guidance on how a company should apply the definition provided if the company's definition is different. Also we feel a better, Business Northern Reporter 

more descriptive definition is required. 

America 

However yes in principle - we recognise GRI's aspiration for value chain disclosure but feel this is too much of a leap too soon. Mediating 

Institution 

Europe 

Consultant 

Report Reader 

I consider the list of persons and organizations included in the proposed definition of “supplier” to be superfluous. Particularly, I 

think that “home workers” and other individuals included in some categories of a supplier should be removed. I believe that such a 

wide definition of the notion “supplier” would prevent effective information disclosure for some indicators, and will require 

considerable resources investments in performance evaluation resulting in insignificant findings. 

Financial 

Markets & 

Information 

Users 

i. Could consider using the ISO 26000 definition, to have one less definition around, as they seem to be rather comparable. Mediating 

Institution 

In “Supplier” the “indirect” provision of services should be defined, and then also mentioned in the “Supply chain”. Consider that Mediating 

companies often have a “supplier ledger” in which they register invoices (that is “direct” provision only). Also, GRI should define if Institution 

“active” and/or “non active” suppliers are considered and further define this term (i.e. “active” in the reporting period, since the 

supplier registry holds both categories). 

Europe 

Europe 

Europe 

Reporter 

Consultant 

Consultant 

Assurance 

Provider 



Page 1159 of 2491


Relationship 

There should be more focus on the significant suppliers (in terms of dimensions and operations) which requires a clear definition of 

which suppliers could be classified as “significant” (i.e. in terms of sales, cost of goods sold, transactions, nature of goods or services 

provided etc). 

Overall, the definition of supplier is quite broad. It may be useful to subdivide the category of suppliers by relevance of each supplier 

or by relevance of a specific kind of supplier (by country or category). 

Position of home workers (as well as the utility providers to these workers), needs to be clearer. In some countries these are not 

classified as formal ‘suppliers’. Consider also recycling companies that bring back a % of materials into the production process? 

In general, it is appropriate but it should be more clearly stated, how far in the supply chain the suppliers should be taken into 

account – is it only tier 1 and 2 or even further? 

Is the definition for supply chain too narrow? Should it also include the demand side of the supply chain so that it reflects the 

definition of how companies define supply chain? 

Mediating 

Institution 

it is newly expanded to encompass entities well beyond our control or influence. Business Northern 

America 

N/A 

Mediating Asia 

Institution 

Partially 

- Supplier: “An organization or person that provides materials, products or services directly or indirectly to another organization. …” 

==> Unclear what “indirectly” means – 2nd, 3rd tier supplier? 

Europe 

Reporter 

Consultant 

Assurance 

Provider 

Report Reader 

Reporter 

Reporter 

Consultant 

Assurance 

Provider 

Report Reader 


- Supply Chain: “The part of the value chain which consists of the sequence of suppliers and activities that provides materials, 

products or services to an organization.” 

==> “Sequence of suppliers” indicate n- tier suppliers. Generally, the “non-manageability” of higher-tier suppliers should be 

considered 

Partly 


• The definitions are generally appropriate. 

• Wherever feasible, GRI could consider to align the definitions more closely with ISO 26000. 



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Relationship 

• The list of suppliers presented in the G4 draft focuses mainly on indirect suppliers, while the majority of direct suppliers like 


Partly 


• Thedefinitions are generally appropriate. 

• Wherever feasible, GRI could consider to align the definitions more closely withISO 26000. 

• The list of supplierspresented in the G4 draft focuses mainly on indirect suppliers, while the majority of direct suppliers like 


Partly. 


The definitions are generally appropriate. 

Wherever feasible, GRI could consider to align the definitions more closely with ISO 26000. 

The list of suppliers presented in the G4 draft focuses mainly on indirect suppliers, while the majority of direct suppliers like 


Partly. 


The definitions are generally appropriate. 

The list of suppliers presented in the G4 draft focuses mainly on indirect suppliers, while the majority of direct suppliers like 


Please refer to the feedback provided by IPIECA, which we support. Business Europe Reporter 

Proposed definitions are not so clear and could provoke missunderstaning for reporting companies as well as difficulties for 

reporting. Proposed reporting scope is quite broad and must be limited to those suppliers that the company affects direclty. 


Apart from that: 

-Not clear consideration of "indirectly" (2682) 



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-Not feasible to display entire list and information of raw materials for retail companies (2700) 

-Not feasible to display entire list of suppliers due to confidential agreements (ADD EC9) 

The “supplier” definition is generally appropriate. However, the “supply chain” definition is not. It is suggested that the definition 

text “The part of the value chain which consists of” be removed from the latter because the value chain reference introduces 

significant confusion and expands the scope of the term so much as to challenge its practical application. 

the definition is complete but it is not appropriate. By including sub-contractors (suppliers of suppliers) it goes too far. The company 

cannot possibly control or even know in such complete and detailed way what happens in all the chain of suppliers / sub 

contractors. 

The definition is complete. But how should a large company seriously give information as asked in DI 12? Even if they have the 

information, what we doubt, it means too much effort to report about it. And are the stakeholders really interested in that depth? 

The definition is very broad. In reality, the influence and therewith the level of control companies have will differ throughout the 

supply chain. The concept of materiality is not included in this definitions and the reporting requirements that result from them. 

The definition of "supply chain" is appropriate, but the definition of "supplier" is not appropriate since it includes both direct and 

indirect suppliers. A supplier to an organization provides materials, products or services directly to that organization. A third party 

that provides materials, products or services to the supplier is not a supplier to the organization. By including indirect suppliers, the 

proposed definition is far too broad and would include parties with which the organization will have no contractual relationship and 

could, in theory, include millions of entities involved in some aspect of the supply chain. 

The definition of “business partner” (which is to a large extent used together with “supplier”) should be included when it is first 

mentioned and in the general Glossary and not only in the Anti-corruption Thematic Revision. 

The definition of “other business partner” (which is to a large extent used together with “supplier” should be included when it is 

first mentioned and in the general Glossary and not only in the Anti-corruption Thematic Revision. 

The definition of “other business partner” (which is to a large extent used together with “supplier” should, however, be included 

when it is first mentioned and in the general Glossary and not only in the Anti-corruption Thematic Revision. 







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when it is first mentioned and in the general Glossary and not only in the Thematic Revision Anti-corruption. 


when it is first mentioned and in the general Glossary and not only in the Thematic Revision Anti-corruption. 

The definition of “other business partner” (which is to a large extent used together with “supplier”) should be included when it is 





first mentioned, and in the general Glossary, and not only in the Anti-corruption Thematic Revision. 

The definition of supplier is very comprehensive and does not take into account the issue of materiality resp. report focus. The 

definition of suppliers should 

a. indicate that the sustainability report should focus on significant/material/relevant suppliers. 

b. differentiate which level of suppliers should be taken into account (tier 1, tier 2, tier 3 etc.) and where to set the boundary. 

The guidelines should also include minimal guidance and external references on how to identify significant/material/relevant 

suppliers. 

The definition of supplier may be overly broad so as include all contributions to the material and service needs of modern 

corporations. 


America 

Reporter 


America 


America 



America 


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Business 

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Northern 

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Report Reader 

The definition of suppliers is clear. 


With regards to supply chain, in guidance section of D1 12 (pg 29) we do not believe total number of suppliers is a valuable 

indicator, and requires extensive resources to report accurately. 

The definition of supply chain does not tell an organization how far down the supply chain they should go. The definition of “other 

business partner” (which is to a large extent used together with “supplier” should, however, be included when it is first mentioned 

and in the general Glossary and not only in the Anti-corruption Thematic Revision. 

The definition of supply chain is fine. The definition of supplier is way too broad given two factors: it includes direct and indirect 

and the use of the term "significant supplier" has been eliminated. Such a broad definition of supplier completely flies in the face of 

materiality by requiring companies to report on all entities in their supply chain regardless of the risks posed by the supplier. 

The definition of supply chain refers to value chain and I consider that the value chain isn't well defined, hence supply chain in turn 

is not defined adequately. 

Re the supplier definition, I feel the examples are unnecessary and don't add value. My recommendation would be to exclude them. 

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I feel that for the G4 the GRI should try and make the guide much more concise and succint and in that way make it much more 

useable. To this end, all unnecessary wording should be eliminated. 

The definitions “supplier” and “supply chain” are very broad. They range from “contractors” to “sub-contractors”. The definition of 

suppliers will have a significant impact on the amount of data and the possibility to evaluate the data. Such data is not available in 

the systems and systems will have to be adjusted. Furthermore, the “types of suppliers” needs to be defined (e.g. service supplier? 

supplier of goods?). The term “existing suppliers” is not specific enough (e.g. active suppliers or all suppliers?) 


Further comments on this are made e.g. on p.53 (EC6), p.64ff (G4 5ff). 

The definitions of “supply chain” and “supplier” are generally appropriate and helpful, except for the confusion related to “value 

chain”. Please see comments below on the terms “value chain”, “stakeholder” and “parties”. The definition text “The part of the 

value chain which consists of” may not be required. 

The flexibility to determinate the depth and scope of supply chain must be left to each reportee. In their evaluation of the 

stakeholders need for informations and concerns the exact approach to determinater the reportee value change definition will 

come up clearly 

The G4 draft Glossary specifies that suppliers can be companies (obviously small or large) or individual consultants or home workers. 

Supply chain related indicators (e.g. under Screening and Assessment) ask for the percentage of suppliers meeting certain criteria. If 

there are a few large suppliers, and a large number of single-person suppliers, a small "percentage" number might mean almost all 

of the supplies purchased. And it would often be impossible in practical terms to get numeric information on the exact number of all 

suppliers, if this includes very small contracts. To make the definitions and indicators meaningful, percentage information should be 

changed to proportion of purchase value, or suppliers should be changed to significant suppliers (defined as having a high 

contribution to purchase value). 

The inclusion of the words indirectly in the supplier definition is too broad, too vauge and reporters would struggle to define this 

adequately. Suggest this be removed from the definition 

The removal of the term “significant supplier” is problematic (page 77 line 969, p. 78 line 972 and elsewhere, definition on p. 230). 

Given that the guidance on how to define supply chain does not specify mapping only “significant” suppliers, the resulting 

disclosures on all suppliers would be impractical. 

p. 315 lines 2693-2696: As currently worded, this definition of “home workers” would include employees telecommuting from home 

- these are employees, not suppliers. Suggest revising this definition. 

The supplier concept is appropriate for downstream analysis, but it does not reflect the need to look upstream as well (clients). In 

actual facts the screening cannot be limited to the supply chain, but also need to be extended to the clients. Some of the indicators 

need to be specifically extended to the upstream chain (the clients). You do want to know if the clean pieces of metal produced are 

then used to manufacture dirty bombs 

The supplier definition sets a very broad scope. Recommend allowing categories within this definition, and allowing companies to 

report on different categories individually, as long as they specify the category on which they are reporting. 



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The term ‘indirect supplier’ needs to be more clearly defined. This could lead to an extremely long list for larger organisations. A 

boundary needs to be defined, and examples might also to be included. Additionally it is worth noting whether or not such a process 

is really necessary, therefore asking the question: Had it not been there, would it make a difference? 

The term “other business partner” is used and should be defined. 


Accountancy 

body 


America 

Hess also concurs with the following response to this question submitted by IPIECA: 

The definitions of “supply chain” and “supplier” are generally appropriate and helpful, except for the confusion related to “value 

chain”. Please see comments below on the terms “value chain”, “stakeholder” and “parties”. The definition text “The part of the 

value chain which consists of” may not be required. 

The term “vendors” appears to be missing from the list of subcategories of suppliers 

the term supply chain as well as supplier shall be refer to existing term used globally, which is used in ISO 9000 glossary and ISO 

26000 

The use of "direct and indirect" together in a single definition for supplier probably needs more examination. In practice, companies 

with thousands of suppliers "tier" suppliers by risk and strategic importance to prioritize screening and there are different activities 

you would prioritize for direct vs. indirect suppliers since level of control and influence differs greatly. 

To be completed: Public authorities should be considered as licences suppliers. 

To make tehses definitions useful and meaningful, percentage information in the supply chain related indicators should be changed 

into proportion of purchase value, or suppliers could be changed to significant suppliers (being the ones with trong part of purchase 

value). Otherwise companies with a large number of small suppliers (home workers, individual consultants etc) would have to 

report on almost all their (party very small) suppliers with eventually very small contracts- In practice it is often impossible to get 

valuable numeric information on the number of all suppliers with these terms. 

To us it is unclear how far the individual responsibility extends and what is meant by supplier - do you mean the direct supplier (the 

first link in the chain)? For a small or medium-sized enterprise it will be extremly difficult to comprehend all suppliers (e.g. the thirddegree 

suppliers and upwards). 

We appreciate the fact that both selection and monitoring of supplier are taken into account, and that the exposure draft requires 

transparency about the audits undertaken. 

Mediating 

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for academic 

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On the other hand, the definition of supplier is probably too wide and does not introduce any difference among direct suppliers, 

sub-suppliers, contractors, sub-contractors and consultants, but those categories have different specificity. 

It would probably be useful to distinguish among strategic suppliers and regular suppliers, and to give specific information on subsuppliers 

and consultants, if material. 

We consider that the definition of supply chain for non industrial companies should be more detailed. (the usage of examples would 

be a good practice) 

We consider too broad and imply a burdensome task to reportees, especially on new reportees and SMEs. Not to mention that in 

developing countries that obligation to expand the scope of report will generate pressure and conflict of interest to the organization 

We consider too broad and imply a burdensome task to reportees, especially on new reportees and SMEs. Not to mention that in 

developing countries that obligation to expand the scope of report will generate pressure and conflict of interest to the 

organization. 

We suggest to include a definition of 'value chain' and the difference or similarity with 'supply chain'. 

Information 

Users 

Mediating 

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Civil Society 

Organization 

Mediating 

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Latin America 

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Mediating Latin America Consultant 

Institution 

We think the definition of supplier es too wide and not always applicable to every kind of organization. The definition of supply Business Europe Reporter 

chain is too brief, and with lack of accuracy. Maybe, this definition should include concepts as Tier 1 and Tier 2 suppliers. 

What do you mean by "home office"? Is it considered regarding flexible working conditions at the suppliers? 

Suppliers could be divided into suppliers of "built-in" materials, and suppliers of other services and materials (like office supplies 

etc.) Higher emphasis should be given to suppliers of built-in materials. 

Mediating 

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Yes, but "other business partner" needs to be clarified. Business Africa Reporter 



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- a broker should not be considered a supplier (the same for a distributor) once its role is mostly to distribute products and services, Business Latin America Reporter 

it plays an important but intermediary role in the supply chain. 

- brokers and distributors should not be excluded from the supply chain but not included as a supplier. 

- The definition of supply chain is too simple and since there are too many different sectors with different definitions of supplier and 

supply chain, I believe a more detailed description would be more effective, mostly showing the differences between service and 

productive sectors. 

- Questions emerged about the boundary and definition of the supply chain. The GRI should take the ISO 26.000 in consideration. Business Europe Reporter 

: Clarity in terminology is required: The glossary section could refer to the definitions given in ISO documents for certain 


Mediating 

Institution 

Asia 

Reporter 

Report Reader 

: Clarity in terminology is required: 

Business Asia Report Reader 

The glossary section could refer to the definitions given in ISO documents for certain terminologies used in various areas of the 

G4 Guidelines such as sustainability topic, aspect, impact, value chain, supply chain, etc 

Clarity in terminology is required : The glossary section could refer to the definitions given in ISO documents for certain 

terminologies used in various areas of the 

G4 Guidelines such as sustainability topic, aspect, impact, value chain, supply chain, etc. 










Clarity in terminology is required. The glossary section could refer to the definitions given in ISO documents for certain 

terminologies used in various areas of the G4 Guidelines such as sustainability topic, aspect, impact, value chain, supply chain and 

other such terminologies. 




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G4 Guidelines such as sustainability topic, aspect, impact, value chain, supply chain, etc 

Clarity in terminology is required: Business Asia Report Reader 



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Business Asia Assurance 

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clarity is terminology is required Business Asia Report Reader 

clarity is terminology is required 




Comment 1: Clarity in terminology is required 


Consultant 

The glossary section could refer to the definitions given in ISO documents for certain terminologies used in various areas of the G4 Institution 


Companies, even large, may not be able to respond to these indicators, including division by gender. 

The Brazilian reality does not match this level of detail. 

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Each company's materiality assessment should define the composition of its supplier group. 

It should not report on immaterial suppliers. 

For large companies, it is virtually impossible to report on all suppliers. For reporters is extremely necessary a definition of 

“significant suppliers” that must be used in indicators. 





I find the definition of supply chain limited because it is too concentrated on the upstream side. There is not mention of 

downstream stakeholders such as customers, clients, etc. In addtion, refering to supply chain as part of the value chain is ambiguos 

and confusion. 

"Value" in an indian context may have a very spiritual connotation, thus not very objective, practical or tangible. 

Mediating 

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Asia 

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Former report 

preparer. 

Current 

Academic 


Report Reader 


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Markets & 

Information 

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Mediating 

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Asia 

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Consultant 

A combination of the two definitions (value chain and supply chain) may be more user-friendly and appropriate 

In my view Supply Chain is the complete production chain from resources till customer (end user). In your definition you only take Mediating Europe 

Reporter 

suppliers into account. If you think of recycling, cradle to cradle concepts and/or life cylce management the end user is a vital part of Institution 

Consultant 

the supply/value chain. 

Supplier: definition ok 

In the definition is missing chain of cost (Traceability) 

Civil Society Latin America Reporter 

Organization 

In the definition, it is missing cost chain (traceability) Business Latin America Reporter 

In the definition, it is missing cost chain (traceability) 


Institution 



Include supplier distance fator thinking about the environment and locla economy Business Latin America Reporter 



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Include supplier distance fator thinking about the environment and locla economy 


Organization 






missing traceability (chain of cost) 

Mediating 

Institution 

Latin America Report Reader 

Academic 

research 

My comments are confind to the issue of definitions. I consider that Value Chain and Supply Chain as used in the Exposure Draft do 

not provide a suitable basis for identifying sustainability impacts. 

Incorrect definition of Value Chain 

The definition given in the Exposure draft not corresponding to accepted definitions of Value Chain. 

The Exposure draft defines Value Chain as: 

“The value chain consists of the parties that are linked by the organization’s activities, products, services, and relationships, and may 

therefore impact and be impacted by the organization. The perspectives of stakeholders should be taken into consideration when 

the organization maps its Value Chain. “ 

This definition omits the concept of value-added outputs which was the basis of Porter’s concept and is in fact simply a supply chain 

definition (supply chain covers the whole of the life cycle of products and services). 

An example definition of value chain is “the sequential set of primary and support activities that an enterprise performs to turn 

inputs into value-added outputs for its external customers. As developed by Michael E. Porter, it is a connected series of 

organizations, resources, and knowledge streams involved in the creation and delivery of value to end customers.” 

The GRI definition of Supply Chain narrows it to upstream 

There are various definitions of Supply Chain but often, a supply chain is defined to indicate flows or a process in the whole life cycle 

of a product or service, from origination to end use and then disposal. 

However, the Exposure Draft definition limits Supply Chain to upstream only. 

“The part of the value chain which consists of the sequence of suppliers and activities that provides materials, products or services 

to an organization.” 

The GRI focus should be on sustainability impacts in the whole life cycle of a product or service – the GRI should use the 

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Sustainability Chain 

For sustainability management, the interest is in the impacts – beneficial and adverse – that happen within a process – this will be 

by exercising sustainability responsibility or countering risk. Supply or Value chains are not the best process structures for such 

purposes. 

Thus, for child labour, organisations would use a Sustainability Chain to show the process element where there is risk of child labour 

being used. 

Specific Chains can be developed. For countering corruption, I have developed the concept of a Corruption Chain - corruption risk 

occurs wherever there is a movement or transaction e.g., in steel supply, moving steel plate from one warehouse to another may 

not add value but it presents a risk that high quality steel will be substituted with inferior steel. 

In a Value Chain the identification of the process stage is that value is added but the Value Chain gives no other benefit to 

sustainability reporting. The absolute value added is no guide to the sustainability impact. 

The Global Compact in its publication Supply Chain Sustainability: a practical guide for companies says:”Supply chain sustainability is 

the management of environmental, social and economic impacts, and the encouragement of good governance practices, 

throughout the lifecycles of goods and services. The objective of supply chain sustainability is to create, protect and grow long-term 

environmental, social and economic value for all stakeholders involved in bringing products and services to market.” 

So, I think the concepts of supply and value chains need rethinking for sustainability reporting. A revised terminology such as 

‘Sustainability Chain’ is needed. 

No: 

-Home workers (=employees working from home) are not suppliers; however, e.g. utility provider of such home workers are, 

although indirectly, some kind of suppliers 

Mediating 

Institution 

Europe 

Assurance 

Provider 

-What about recycling companies who bring back a % of materials of used products in the production process? 

Questions emerged about the boundary and definition of the supply chain. The GRI should take the ISO 26.000 in consideration. Business Europe Reporter 

some more clarity required Business Asia Reporter 

Supplier definition should allow reporter to set thresholds by volume, sales, etc., rather than count individual providers 


Consultant 

Institution 

Report Reader 

supply chain: "The part of the value chain which consists of the sequence of suppliers and activities that provides materials, 


Reporter 

products or services to an organization." Generally the supply chain includes the flow of goods FROM an organization as well as TO Institution 

Consultant 

an organization. supplier: home worker needs clarification - they are only suppliers if they are not on the payroll. Not sure why there 

Assurance 

is a need to identify this as a separate group. 

Provider 

Report Reader 

the complexity of the subject and the differences between organizations cause that the definition cannot be complete. (more Mediating Europe 

Reporter 

examples for different organizations would be a good solution) 

Institution 

The definition do not take care of suppliers suppliers. A supplier may be a trading agency who sources material from different 

suppliers. How does the definition covers the actual manufacturers? Supplier shall be defined as an entity who supplies materials, 

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products and services with significant value of the supplied material, product or service is created within the boundary of the 

supplier. 



The definition of Supply chain - to a network of organizations (e.g. manufacturers, wholesalers, distributors and retailers) involved in 

production, delivery and sale of a product to consumer. (Ref: GHG protocol scope-3 supplement-2011). 

Since we are now moving towards the integrated approach of reporting it should be in line with ISO, WRI/WBCSD GHG protocol, etc. 

The definition seems in order (upstream part of the value chain). A better phrase for "materials, products and services" is "goods 

and services" (which captures all of the former). The listing of types of suppliers could be reconsidered - possibly listing 1st large 

organisational suppliers and only thereafter items that refer to smaller organisations and individuals (eg home workers, 

independent contractors, consultants). Structure ito of the supply chain flow / logic of (i) planning, (ii) sourcing, (iii) making and (iv) 

delivering; or raw material / goods & services supplies, transportation, manufacturing, distribution and retailing. 

The extents of disclosures related to management approach are too elaborate. It is not clear as to what depth a topic / aspect needs 

to be assessed and disclosed. Management disclosure has become complex and may lose essence of reporting; however there is 

scope to simplify the disclosures. 

Additional 

• Top Management requirement to verify accordance with GRI Guidelines and presentation of organization’s sustainability impact: - 

The GRI Guidelines is a voluntary initiative by an organization. The understanding from our end is that organizations would not be 

willing for such a requirement to be placed on the Top Management when even statutory disclosures such as financial statements of 

an organization do not require such a sign-off from the top management of an organization. This requirement does not reflect 

understanding of ground realities. Data availability and quality issues along value chain will never result in a sign off. Moreover, if a 

company publication is not trusted, where does it stop being voluntary 

• Listing out the exclusion from the report in CEO Statement: - The 'In Accordance' criteria list out the requirements for the CEO to 

state any exclusions relating to Points 1-3. In the first case, the Boundary Disclosure already state organizations to explain the 

omissions that will not be considered in the report. 

The guidance given under the GHG corporate value chain assessment gives much clearer supply chain guidance, as the proposed 

guidance leaves too much avaliable to interpretation 

The international definition of supply chain and value chain is different from the one used in the proposed text. In this case, supply 

chain means: "Supply chain management (SCM) is management of a network of interconnected businesses involved in the provision 

Training 

partner 


Report Reader 

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Reporting as a 

condition of 

membership 


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SustainAbility 

std., ISO-14064 

Lead verifier, 

ISO-14001 

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of product and service packages required by the end customers in a supply chain.[2] Supply chain management spans all movement 

and storage of raw materials, work-in-process inventory, and finished goods from point of origin to point of consumption" 

Assurance 

Provider 

So, when we say Supply chain is till de end user. Not from the provider to the company. From the "CRADLE TO THE GRAVE". ThAT 

should be the concept of supply chain and not only from the provider to the organization. 

AND VALUE CHAIN, FROM PORTERS DEFINITION is not what GRI is proposing: "is the sequential set of primary and support activities 

that an enterprise performs to turn inputs into value-added outputs for its external customers. As developed by Michael E. Porter, it 

is a connected series of organizations, resources, and knowledge streams involved in the creation and delivery of value to end 

customers. Value systems integrate supply chain activities, from determination of customer needs through product/service 

development, production/operations and distribution, including (as appropriate) first-, second-, and third-tier suppliers. The 

objective of value systems is to position organizations in the supply chain to achieve the highest levels of customer satisfaction and 

value while effectively exploiting the competencies of all organizations in the supply chain" 

Too much overlap between "supply chain" and "value chain" definitions. 

Top Management requirement to verify accordance with GRI Guidelines and presentation of organization’s sustainability impact. 

The GRI Guidelines is a voluntary initiative by an organization. The understanding from our end is that organizations would not be 

willing for such a requirement to be placed on the Top Management when even statutory disclosures such as financial statements of 

an organization do not require such a sign-off from the top management of an organization. This requirement does not reflect 

understanding of ground realities. Data availability and quality issues along value chain will never result in a sign off. Moreover, if a 

company publication is not trusted, where does it stop being voluntary 

Mediating 

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Comment 2: Listing out the exclusion from the report in CEO Statement 

The In Accordance criteria list out the requirements for the CEO to state any exclusions relating to Points 1-3. In the first case, the 

Boundary Disclosure already state organizations to explain the omissions that will not be considered in the report. 

way, WAY too broad. At the Stakeholder Council meeting I was astonished at how much people underestimated what this type of 

reporting would entail. Supply chain reporting should reflect supply chain management. If that then makes it clear that supply 

chain management is inadequate, management is exposing potential risks that investors and other stakeholders should 

appropriately consider. 

We believe that the definitions of “supplier” is too much extensive. It won’t be easy for a company have for several categories of 

suppliers.Maybe would be more appropriate require a deeper analysis for the most important suppliers ( e.g. the suppliers 

classified like “strategic” for the core business or the over a specific threshold of expenditure) 

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What about utility providers? 


Consultant 

Institution 

Why is it that in detailing of supply chain- only issues related to 'receipt' (including materials, people, transportation etc.) is 

considered but not more so on 'dispatch' related issues (partial of Scope 3 and not complete assessment). 

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§ Questions emerged about the boundary and definition of the supply chain. The GRI should take the ISO 26.000 in consideration. Business Europe Reporter 



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Q2) Do you consider the proposed supply chain-specific Indicators to be effective measures for performance and feasible to 

report? 

Yes 




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• ERM supports the addition of supply-chain specific Indicators. However, there is significant overlap between many of the 

indicators. ERM suggests that GRI include a new indicator category just for supply chain to streamline some of these indicators and 

align with how companies actually manage these issues. 

• It is extremely important to link this back to “Part 4: Technical Protocol for Defining Report Content and Boundaries” which guides 

on how the materiality principles should be applied, as the significance and/or relevance of indicators such as “total number of 

suppliers” or the “total monetary value and/or volume of materials, products and services purchased directly from suppliers” would 

vary depending on the sector and/or company. 

• Without this repetitive linkage, words such as “Total” would seem contradictory to G4’s principle of reporting on only the material 

issues. Adding a few extra words to explain the context and/or scope of “Total” in light of what is deemed material would be 

helpful. 

• Monetary value of spending on supplier is currently problematic for our sector (power). Our most material suppliers are our fuel 

suppliers, and to disclose our spending on fuel is commercially sensitive, and can/may breach our contract confidentiality 

agreements as well as create conflict with our suppliers. 

• The indicators do not seem to have taken into account situations which the organisations do not have a lot of leverage over their 

material suppliers. It might be useful to request information on whether the suppliers deemed material to the business have 

Mediating 

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Northern 

America 

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leverage/power of influence over their suppliers or not, to help establish whether this is more of a strategic risk or opportunity for 

them. 

• The level of detail required by many of the supply-chain-specific indicators is fairly onerous. For example, the data collection effort 

required to: “report the percentage of total monetary value of spending on locally-owned suppliers at significant locations of 

operations” (line 680-681) or the “average number of days taken to pay supplier invoices” (line 696) may be significant for 

companies with large numbers of suppliers and variable types of suppliers. 

We suggest: that the GRI particularly weigh comments about supply chain indicators received from companies with large and 

complex supply chains, especially with regard to the feasibility of information collection, before including these indicators as 

required/core disclosures. 

• There is considerable repetitiveness and duplication for supply chain-related indicators under the new “Screening and 

Assessment” and “Remediation” Aspects in the Environmental, Labor, Society, and Human Rights categories. Each of the following 

indicator sets (see bullets below) asks for essentially the same information. 

o G4 5/G4 8/HR2/G4 12 

o G4 6/G4 9/G4 11/G4 13 

o G4 7/G4 10/HR 11/G4 14 

The one changing variable in the above indicator sets is that the performance in question is related to the Category in which the 

indicator resides. 

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We suggest: that the GRI organize all of these related indicators in a new section, rather than duplicating the same questions over 

and over again. The combined indicators could cover the entire range of potential supply chain impacts—a reasonable approach 

given that screening, assessment, and remediation of supplier environmental, labor, human rights, and society-related issues do not 

take place removed from each other in space and time. The GRI G4 Guidelines should recognize the integrated nature of many 

companies’ approaches to supply chain issues and structure assessment/screening/remediation disclosure accordingly. 

• The set of indicators is somewhat effective to measure performance. But it is not feasible to report. 

• For large companies with multiple suppliers, such detailed disclosure is a big challenge. Also for many SME the disclosure will be 

not feasible. It will be difficult to align the proposed disclosure with the objective to encourage more companies to report on ESG 

aspects with GRI G4. 

o An example for this is indicator DI 12, which requires a description of the supply chain. This would require not only considerable 

effort for reporters, but also the willingness of suppliers to provide information. This puts the feasibility of reporting “in accordance” 

into question. 

o Also the disclosure on the procurement practice will be extremely difficult for large companies to report accurately and in a 

timely fashion. 

• It would be useful to focus on the most meaningful indicators (e.g. the percentage of suppliers screened or assessed on 

sustainability issues, broken down in a meaningful way as defined by the company) instead of trying to cover every single potential 




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sustainability aspect. The comprehensive approach underlying the G4 draft generates considerable effort, since reporters must 

provide explanations for all issues which are not deemed material or feasible to report. 


• For large companies with multiple suppliers, such detailed disclosure is a big challenge. Also for many SME the disclosure will be 












EC6: 

• We ask for local sourcing but not with regard to ownership. Locally owned, requires a definition of owned. Is locally owned a 

company which is led by locals and in possession of locals? Value of this indicator – to some companies not effective. Main point we 

are sourcing where we are producing. We usually do not select local suppliers by local ownership. 

• Significant locations of operations might have nothing to do with the importance of the supplier 

• Other forms of economic inclusion: not effective for multinationals. If you have 100.000 suppliers we do not ask for information as 

detailed as described by GRI. It might appear within the scope of community relations, that e.g. companies in the surrounding area 

of a production site who especially work with handicapped people are chosen as supplier. But global procurement does not 

differentiate those kinds of ownership in their supplier selection. 

G4 12 

• In principle: effective and feasible 

• Regarding MNEs the categories are usually part of the aspect named here; GRI does differentiate between Categories and has built 

an indicator for each category and aspect. Category consideration might be more interesting with regard to different countries. 

Category assessment might be integrated in aspect management systems of SCM. 

• Remediation Aspect and indicators. Why are in G4 7 suppliers not indicated specifically, although G4 5 and 6 are related to 

suppliers specifically? Who are other business partners? Please define. 

• ADD G4 4 is not feasible for Conglomerates, we e.g. have 70.000 product groups/families – monetary value is supplier-related and 

not material-related. One material group might have different suppliers. Indicator might also be problematic from an anti-trust 

point of view. 


• For large organizations with multiple suppliers, suchdetailed disclosureis a big challenge. Also for many SMEthe disclosure will be 

not feasible.It will be difficult to align the proposed disclosure with the objective to encourage more companies to report on ESG 





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effort for reporters, but also the willingness of suppliers to provide information. This puts the feasibility of reporting “in 

accordance”into question. 

o Also the disclosure on the procurement practice will be extremely difficult for MNEs to report accurately and in a timely fashion. 




provide explanations for all issues which are not deemed materialorfeasible to report. 

•The set of indicators is somewhat effective to measure performance. But it is not feasible to report. 

•For large companies with multiple suppliers, such detailed disclosure is a big challenge. It will be difficult to align the proposed 

disclosure with the objective to encourage more companies to report on ESG aspects with GRI G4. 

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•It would be useful to focus on the most meaningful indicators (e.g. the percentage of suppliers screened or assessed on 




Although the proposed supply chain-specific indicators appear to be effective measures for performance, for some of them (e.g. 

those referring to the indirect adverse impact that the organization has on the environment across all of its suppliers or ADD G4 4) it 

will be difficult and sometimes nearly impossible to collect the necessary data, and these indicators might be only partially (or not at 

all) reported. In our opinion, directing companies to focus on a portion of its suppliers only (e.g. by amount of spend or by risk 

associated with using a supplier) would make supply chain reporting more feasible and assurable. 

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Indicators G4 1 (Spending on suppliers with which long-term agreements exist) and G4 2 (Percentage of suppliers with which orders 



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were placed for the first time during the reporting period) should not be core indicators if every organization will have to report 

these to be in accordance with G4 since too much detail is required for large organizations and some of these disclosures could be 

confidential. 

An organization should not expect to save the world with their report!! 

G4 changes the responsibility, now an organization is responsible to justify which scope they report on. 


Therefore, we regard the aim of scoping too extended. The aim should rather be to focus on areas under the company's sphere of 

influence. 

Anglo American is committed to managing our supply chain and accepts our responsibility in this regard. However, Anglo American 

is right at the front end of the supply chain and is a consumer of a number of process materials and equipment used in mining - this 

lends itself to very different issues than companies that, for example, outsource all their manufacturing. We believe that the new 

inclusions are more suitable to the latter with a far more direct responsibility for their supply chain. 


If there was a specific section on SC management, then companies like Anglo American could argue that many of the indicators are 

not material. However, many of these are integrated into existing indicators and can therefore not be isolated as not material. 

Generally, our suggestion would be to revise the entire approach to SC indicators and inclusions to be far more general and strategic 

(though we do agree they need to be more extensive than in G3) and then include the more extensive requirements in relevant 

sector supplements. Alternatively, they should be removed in sector supplements where the issue is less material. 

Additional concerns: 

- the requirements are extremely onerous and would add very little value to the business. 

- they focus on data and not performance. For example, instead of asking how many suppliers (we have over 50,000) in which 

countries (we have suppliers in dozens of different countries) may have potential/actual environmental impacts, the question 

should be "have you done a risk assessment of high environmental impact suppliers? If any significant risks arose in the assessment, 

what are you doing to address them? 

- it is unclear to whom comprehensive responses to all the questions would add value. We cannot see even the most interested 

stakeholders wanting/having the inclination to, digest these vast quantities of information. 



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- We like that the GRI asks for impacts on our supplcy chain; but we need to remember to include also impact on the company (see 

line 82) 

- We do not think that many new reporters / smaller companies to ever hope to report this level of detail. Our concern is that their 

decision to use the GRI guidelines would be negatively influenced. 

- As a consequence of the SC inclusions, the GRI is now unreasonably weighted in favour of reporting on issue that we do not have 

direct managment control over. This will be compunded by the boundary change. 

As noted before, the performance and training of internal and independent auditors should be part of the reporting. Also, 

companies should note where there have been violations missed by an auditor. Also, you talk about general data on number of 

employees, but later in the document talk about data disaggregated by gender. It's clear you expect data disaggregated by gender 

throughout, but the inconsistency in where you ask for may cause confusion. It's very helpful in an overview to know whether a 

company's employees are 90% men and its supply chain employees are 75% women. It suggest possible issues at a broad scale. 

As noted in a previous response, the proposed guidance mainly shows guidance on each element, but in doing so it falls short in 

articulating the idea that each element should be evaluated from the viewpoint of contribution to value creation and preservation. 

This concept would serve as helpful guidance toward company application of materiality in the context of GRI reporting. 

As presented I consider it will be very difficult for companies to report . The reporting of supply chain information should be specific 

to stakeholders relevant needs. Trying to devise general indicators means in many cases an over kill and in others where it is really 

important, possibly failure to report the relevant information. 

Either way, the risk is that for the majority of cases supply chain reporting will not be enhanced as presented in the G4 draft, so this 

area needs critical rethinking. There should be more alignment of supply chain reporting with the implication of stakeholders when 

appropriate in the specific cases when it is a relevant issue. 

Asking for information for "all suppliers" goes to far. How does the concept of Materiality apply here? 

Business 

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Also, the indicators itself are not all relevant for a sustainable supply chain and maybe are triggered by some countries only (e.g. 

suppliers from minority groups - which companies are monitoring this worldwide? Are there data protection issues?) 

Better to be focused on the percentage of suppliers screened and its impact, instead of the difference between old and new 

suppliers. 

Considering the remarks given under q1, these indicators can not be reported effectively. 

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Core G4 1, 2 and 3 take what are typically accounting based financial reporting and cash flow measures and applies them in a 

potentially subject manner to other value based purpose. This potentially confuses and may contribute to a loss of focus in 

sustainbaility reporting. Again, G4 4 poses problems of utility in the information presented - there are costs associated with the 

assembling of such data and it is appropriate to apply a filter here of stakeholder value other than a 'good to know'. 

DI12 is only manageable if you have one central ERP system that covers all data. This is very often not the case in small companies 

and would imply significant investments. 


Advocacy and 

research 


Disclosing the monetary breakdown for materials, services and products provided by our thousands of suppliers as well as the 

location of each supplier likely won’t be possible in the near-term. This would be an onerous requirement for larger companies with 

complex supply chains (particularly if they have not yet done this type of disclosure.) In addition, the value of the purchases of some 

materials in the industry may be considered proprietary information. 

Business 

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Reporter 

If the intent is to measure risk and impacts, perhaps data on the spend and locations of top tier or “significant” suppliers only (e.g. 

suppliers that companies spend the most on and/or those that are most material to overall operations) would be both more 

meaningful and feasible. It may also be more feasible to disclose information in percentages (rather than actual spend numbers, 

which may be proprietary). 

Even direct suppliers are constantly shifting and may be difficult for many companies to quantify at any given point in time. 

Including indirect suppliers in the definition would create an impossible task. Once again, the proposed changes would significantly 

increase the burden on preparing a GRI report by having to collect data on potentially tens of thousands of direct suppliers and 

hundreds of thousands of indirect suppliers, yet would provide little useful information about the company itself. 

For us it will not be feasible to report on supply chain-specific indicators. Very detailed information is required. Data are not 

available for our organization. We hire thousands of supplier. It will require lots of work from company just to be in accordance with 

G4. 

G4 4 – percentage of monetary value of each type of materials, products and services purchased that have been verified or certified 

as being in accordance with credible, widely-recognized economic, environmental and social standards 

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Comment: this is difficult to implement for an IT company with a wide range of materials that we purchase. Suggest reversing it so 

that the requirement is to report the credible, widely-recognized economic, environmental and social standards used for 

purchasing, and indicate which materials, products or services purchased that have been found to meet those standards. 

General comment on G4 5, G4 6, G48, G4 9, HR 2, G4 11, G4 12 

The level of granularity is extremely difficult and time consuming for large multi-national companies with a complex supply chain. 

Recommend considering a phase-in approach, giving companies time to set up the systems to meet this requirement for GRI 

reporting, and/or to maintain the A,B, C levels of reporting and match levels of granularity in reporting to a disclosure level. 



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Generally, it appears that many of the new supply chain disclosures, such as reporting the locations of suppliers with “potential” 

impacts to various material issues such as environmental impacts and a host of Human Rights indicators seem to be driven by the 

concept that a reporting organization should take on the responsibility to report sustainability performance for their entire supply 

chain rather than trying to influence sustainable management practices within the supply chain where relevant and practical. There 

is unquestionably several supply chain reporting disclosures which would not be reported on due to legal/liability concerns. The 

cost in human resources and system development required to do so, would be vast with little or no benefit to the reporting 

organization in terms of developing a metric a company could actually manage. 

I consider some of the proposed indicators superfluous and insignificant for an organization’s performance evaluation. For instance, 

I suggest that the “supply chain” should be excluded from DI 11 indicator. I think that CORE G4 3 indicator (Time taken to pay 

suppliers), line 1334, is inappropriate. Time taken to pay suppliers depends on contract terms and doesn’t indicate itself responsible 

or irresponsible attitude to suppliers. Number of delays and total time of delays in payments under contracts should only be 

assessed here. I also consider CORE G4 1 indicator (Spending on suppliers with which long-term agreements exist, line 1275) 

inappropriate. Rates of long-term and short-term agreements with suppliers don’t influence the level of corporate responsibility at 

all since they totally depend on specific needs and circumstances. This can be fully applied to CORE G4 2 indicator (Percentage of 

suppliers with which orders were placed for the first time during the reporting period, line 1304). I suggest these three indicators 

should be removed. 

I considered the proposed supply chain-specific indicators not to be feasible to report. They require a data collection and a data 

check that might be too huge and expensive compared to the expected results. 


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I think the indicators are effective, but not always necessarily feasible. Business Northern 

America 

I think the volume of information called for is excessive and will be difficult and time consuming to obtain. I also think it is 

Civil Society Northern 

duplicative of efforts that suppliers should be expected to make themselves in their own sustainability reports. A better way to Organization America 

handle this would be to simply require companies to disclose the percentage of their suppliers that publish their own reports; then 

name and link to them, and do the same for the ones that do not report. 

i. Several of the indicators are cumbersome to get together (e.g. number of local suppliers - what is local anyway? How does one 

measure it?) and some are so critical that they will not be reported about. Having participated in the German GRI workshop 

recently, we found a strong objection from Industry saying that they clearly don’t support these indicators. 

In alignment with IPIECA’s comments the changes to the supply chain specific indicators are quite significant and require far more 

detailed information than previously. This would be a large undertaking for an organisation of BP’s size with many suppliers. This 

could act as a barrier for companies deciding to continue using the GRI guidelines if it is unfeasible. 

Furthermore the range of information requested may not be an efficient or effective way for smaller suppliers to report 

performance. 

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In some instances the range and granularity of information being requested, in addition to being incredibly hard to collate for a large 

organisation, may be sensitive or confidential. For example, G4.8 & G4.9 request significant additional information regarding 



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suppliers that will be very difficult to collect. In particular, the request for how the information is broken down (namely by location 

of the supplier, the nature of the issue, and the location of the issue) is overly burdensome and may actually lead to the disclosure 

of sensitive information that could exacerbate the situation in question. Again there is not enough direction as to which tiers of 

suppliers this will apply to. 

In HR 2 & 11, it is unrealistic to expect companies to provide this information broken down by location of the supplier, the nature of 

the issue, and the location of the issue. Furthermore it could lead to disclosure of sensitive information and could exacerbate certain 

situation. The same is also true for G4.12 & 13. 

Many of these concerns link back to a lack of guidance on how to prioritise suppliers for disclosures. 

BP supports the development of simplified indicators that address performance around the key areas of management, such as 

screening, impacts and grievance mechanisms. 

In an industrial environment with thousands of suppliers in dozens of countries it is not feasible to report on all suppliers and all 

elements of the supply chain. A guidance on what selection aspects could be used, or even defining standard approaches (e. g. for 

sectors) would be helpful. 

In general, we do not see much value in adopting all of the G4 expectations in our supply chain processes as the definition of 

“supplier” includes certain suppliers (e.g. home workers, primary producers, wholesalers, subcontractors) that we do not deal with 

directly . Therefore, we would have no information on these suppliers in order to respond to indicators such as HR2 - screen for 

human rights abuses etc. In general it will not be practical nor will be of much benefit to the organisation to attempt to report on all 

the supply chain related reporting requirements outlined in G4. 

In regards to the indicators being effective measures of performance, I believe that the indicators do help report users better 

understand the overall relationship with suppliers and the risks and opportunities present in a sustainability context. 

In regards to feasibility, I feel these indicators will create a significant burden to both the reporting company and their suppliers. 

Perhaps reducing the number of indicators, maintaining the initial screening indicators (percentage screened for environmental, 

labor practices, human rights and society and actions taken) and eliminating the remaining indicators. 

In terms of whether the indicators are feasible to report, as the G4 Guidelines include a host of new indicators, particularly on the 

aspects of screening and assessment, and remediation, depending on the nature and extent of an organisation's supply chain, some 

of the indicators will require additional planning and resources from the organisation as well as working with the suppliers and 

other stakeholders in order to implement the measures and provide the necessary data for disclosure. 

Information required about supply chain may be very sensitive and not disclosed, because in some cases the suppliers' degree of 

dependence from the customer (in this case the reporting organization) will be disclosed, and probably suppliers do not want to tell 

to their customers up to what point they depend on them. 

The degree of specificity of information is very high, and will increase considerably the difficulty for obtaining the indicators. 



Business Latin America Report Reader 

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it is too detailed. Information is simply not available at this level especially in decentralized companies. Some concepts are not clear Business Europe Reporter 

(what is a new supplier ?). The “locally owned” definition is too restrictive. Local ownership is not the only criteria to take into 

account to measure the contribution of a company to local development. 

It would great to have all the information required, however, most will pose a significant challenge to source. Business Latin America Reporter 

It´s a great idea to include in the report supply chain-specific indicators, but is necessary do it with criterias like risk or impact 

associated at the relationship between providers and organisation. 


It'll be convoluted to get some information Business Europe Reporter 

Line 1334 on p. 115 (Time taken to pay suppliers): More information may be needed regarding the value or significance of this 

indicator. 

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In general, there may be challenges for organizations to gather the necessary supplier data. For example, holdings companies are 

typically decentralized and supplier arrangements may not be under the control of the holding company, but rather at the 

brand/business level. 

Making reference to SOCIAL and ECONOMIC inclusion remarks the importance of both concepts as relevant forms of inclusion. 

Many of the disclosures presented appear to ask for proprietary information. With the apparent greater focus in G4 on supply chain, 

human rights, and labor issues, specific guidance should be included on how reporters should handle proprietary information, such 

as salary information. Importantly, it should be GRI policy and made clear in the guidance that any information declared proprietary 

by a reporter not be counted against them in being declared an official GRI reporter, especially in light of the revisions to the 

Application Levels guidelines of G4. 

Many of the disclosures presented appear to ask for sensitive information, such as the reason a supplier would be terminated or the 

number of days it takes for suppliers to pay invoices. We do not believe that it is necessary to include sensitive information related 

to our suppliers at Southwest Airlines. Some of our suppliers will likely not support this type of effort. Also, gathering the extensive 

supplier information requested completely and accurately may not be feasible. GRI should allow companies to declare information 

proprietary and opt to not report certain indicators for this reason. And with the new G4 requirements that all profile disclosures 

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must be reported, the supply chain-specific indicators should not be counted against reporters when being considered “in 

accordance” with the GRI guidelines. 

Many of the indicators proposed will be practically impossible for many industries to report at a global level. See comments in the 

Document Review section for some examples. 

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are several supply chain reporting disclosures which would not be reported on due to legal/liability concerns. The cost in human 

resources and system development required to do so, would be vast with little or no benefit to the reporting organization in terms 

of developing a metric a company could actually manage. 




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chain rather than trying to influence sustainable management practices within the supply chain when practical. There is 

unquestionably several supply chain reporting disclosures which would not be reported on due to legal/liability concerns and the 

cost in human resources and system development required to do so while receiving little or no benefit to the reporting organization 

in terms of developing a metric a company could actually manage. This is unfortunate, because there should be a focus on 

sustainable supply chain performance as this is one area than can really drive sustainable environmental stewardship and economic 

empowerment for stakeholders. 



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chain rather than trying to influence sustainable management practices within the supply chain when practical. There is 

unquestionably several supply chain reporting disclosures which would not be reported on due to legal/liability concerns and the 

cost in human resources and system development required to do so while receiving little or no benefit to the reporting organization 

in terms of developing a metric a company could actually manage. This is unfortunate, because there should be a focus on 

sustainable supply chain performance as this is one area than can really drive sustainable environmental stewardship and economic 

empowerment for stakeholders. 








is unquestionably several supply chain reporting disclosures which would not be reported on due to legal/liability concerns, let 

alone the low chance of obtaining reliable information in a timely manner in certain countries or territories which are without 

mature information infrastructure or practice. The cost in human resources and system development required to do so would be 

vast, with little or no benefit to the reporting organization in terms of developing a metric a company could actually manage. 



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cost in human resources and system development required to do so, would be large with little or no benefit to the reporting 




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reports in 

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impacts to various material issues, such as environmental impacts and a host of Human Rights indicators, seem to be driven by the 



is also unquestionably several supply chain reporting disclosures which would not be reported on due to legal/liability concerns. 

The cost in human resources and system development required to report with this detail would be vast, with little or no benefit to 

the reporting organization in terms of developing a metric a company could actually manage. 

Mapping the value chain for a large, diversified multi-national company is extremely complicated. Which business unit? By market? 

Guidance should instruct companies to only focus on what is truly material for their business. 

Most companies, even the larger companies who have the resource and have been publishing a GRI based report for some 

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time, will find the supply chain linked disclosure elements extensive, expensive to assess and find it premature to even start 

looking at some of the indicators. And many of the new indicators on supply chain are marked CORE. There are issues in 

adopting this kind of directive data-intensive approach. It ignores the fundamental nature of deep supply chains and complexity 

in assessing them. Some of these are a) Multi layered supply chain with complex dependencies of local economy and 

livelihoods b) Influence is sometimes dependent on the direct revenue contribution of business relationship with the supplier. c) 



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Language and diversity barriers - communicating ESG is challenging with many of the local suppliers (reporting organizations 

can but only do this progressively). And moreover companies should adopt a non-enforcing enabler approach in their supply 

chain engagement – especially in economies and countries where a uni-dimensional approach on ESG aspects can 

sometimes go against the basic human rights (livelihood and humanitarian) principles in the absence of alternatives coming 

from fundamental and systemic changes in the local economy. The GRI G4 framework, like its predecessor GRI3.1, 

unfortunately seems to advance this unilateral, data intensive, and compliance focused approach to supply chain engagement. 

The reporting framework also seems to assume a certain kind of ‘global organisation’ and supply chain engagement and 

maturity context. For a large global multinational based in a developed economy/region, their supply chain (Figure 1) is 

primarily with a wide range of suppliers in developing economies and to a smaller extent in the home region (developed 

economies). Due to the relative scale (buying power) and the longer duration/process in the development of their global supply 

chain footprint, their global supply chain can be expected to be more mature and geographically dispersed but not necessarily 

deep/multi-tiered. This presents a unique set of supply chain opportunities as compared to a global or large company based out 

of a developing economy with a nascent supply chain engagement (Figure 2). It is important to recognize this when setting 

guidelines for reporting boundaries (and their value/supply chains) and not ignore the history, national/regional context and 

aspects of control/influence with their supply chain. The G4 reporting framework does not provide space for organizations to 

explore and explain this. 

Most of the additions are feasible to report but the addition of screening for social impacts is difficult to asses as there is no defined 

framework to utilise for determining social impacts and what constitutes good performance. 

No. Reporting on supply chain should be related to the risk supply chain poses to the company/ communities. For example, if a 

company operates the the Congo, supply chain management/ reporting should be strong. However, this is not necessary in all 

industries. Best practice askes multinationals to increase local hiring and procurement. In doing so, we have hundreds of vendors -- 

including local farmers who receive micro finance to increase agricultural yields, and our company commits to purchasing a 

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percentage of their crops -- from whom we'd require require information. Not only do they not have the time ro capacity, but there 

is no business value to our company. 

None of these indicators are currently a part of our key procurement performance metrics for our Procurement program, and only a 

few of them are part of our supply chain sustainability approach and reporting. Some of the metrics will be feasible to add, and 

others will be more difficult. 

-Not clear enough economic inclussion (674) 

-Monetary value information of suppliers should be treated as confidential and senstitive information 

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-Procurement Practices (Long time agreements) is going to be difficul to display 

Not feasible at all. 

Original submission received in the Spanish Language: 

Los indicadores deben variar de acuerdo a la organización, no es lo mismo una empresa del sector extractivo que del sector de 

alimentos. 

Submission translated into the English language: 

The indicators should vary according to the organization, as an extractive company is not the same as a food producer. 

Partially 

- For large, complex organizations with more than one business focus, with several supply chains and a global presence the “Supply 

Chain Disclosure” poses severe challenges. 

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- The set of indicators is somewhat effective to measure performance, but it is not feasible to report (amount of KPIs and level of 

detail). 

- We agree that transparency in the supply chain can help to improve sustainability; however we do not think that the problem can 

purely be solved through a more detailed reporting of companies at the end of the supply chain due to resulting immense 

complexity and the limited influence potential to Tier-2 / Tier-3 suppliers. We rather suggest to focus more on encouraging 

companies “at the beginning of the supply”, i.e. raw material suppliers, outsourced manufacturers in developing markets etc to 

increase their reporting efforts. 

- Many indicators would require a significant and unduly investment in time and resource for implementation of data gathering and 

monitoring (ADD G4 4, CORE G4 6, CORE G4 9, CORE HR6, CORE HR7, CORE HR2, CORE G4 11, CORE G4 12, CORE G4 13) 

- Some indicators may impose certain reputational risks to the organization as only risks are reported without addressing the various 

efforts to mitigate the risks (CORE G4 6, CORE G4 9); furthermore comparability between different organizations will not be given 



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- Some indicators are business confidential (CORE G4 1, CORE G4 2, CORE G4 3, CORE EC6); publishing all data would threaten an 

organization’s trade secrets/competitive advantage. 

- We strongly recommend reviewing the section and reducing the disclosure scope, while keeping the above mentioned arguments 

in mind. 


Re feasibility: In order to report fully our organization would require considerable enhancements to our procurement system. The 

level of detail required in the draft G4 on supply chain seems way beyond anything any of our stakeholders have ever asked for and 

includes several items that we consider confidential, e.g. G4 3 time taken to pay suppliers – late payments percentage, screenings & 

assessment – Core G4 5 breakdowns by location of supplier, etc. 

G4 2 - p. 53 – lines 689-693 & p 114 why is it first time “orders”, not first time suppliers? 

Business 

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America 

Reporter 

G4 5 p. 64 lines 753-754 & page 177-8- – Not clear exactly how this could be calculated: e.g. we might screen multiple suppliers and 

only one becomes a new supplier, some of the others might not have passed our screens but were rejected for reasons other than 

the screening results. G4 6 is more relevant and possible to calculate. 

Related to the response to question #1 above, a straight percentage of screening of total direct and indirect suppliers is not likely to 

be a meaningful figure for most companies. Language should be amended to also allow companies to report on the percentage of 

significant suppliers screened (as long as they explain how they tier or segment suppliers to prioritize for screening and capacity 

building activities.) 

Reporting in the way descibed will require significant effort from North American companies. However, we beloeve this to ne a 

necessary step in incorporating corporate social responsibility principles in Nothr American business practices 

Requirements for G5-6, G8-9, G11-12 & HR2 to disclose findings of screenings - location of the supplier & other business partner, 

the nature of the issue and location of the issue - is asking for information that can lead to identification of the supplier which could 

be deemed confidential & could ensue legal risk. 

Business 

Northern 

America 

Reporter 


America Report Reader 


D1 11 (pg 28) - asking for changes in relationships with suppliers, when a company has thousands of suppliers, is unrealistic. It is also 

impractical to identify their locations. Apart from not necessarily holding that information, are we referring to their head office, the 

location of production of their good, location of sale of their good or something else? 

D1 12 (pg 29) seems to be a list of all information one can provide about suppliers, and added value is not clear. As an oil & gas 

company we only work with indirect materials and cannot report on 2a. fully. 



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2c. is also difficult to report. As a large company we have hundreds of suppliers in all countries and regions, it makes no sense to 

simply list them, and even worse to go to the level of location within a country. This also requires us to provide information about a 

supplier that they themselves may not wish to be shared. 

Furthermore the definition of weak zones may be controversial and could strain relations with an organisations stakeholders if they 

are identified as being weak zones. If this is publically available information it is not clear why the reporting company should have to 

report this additional information? 

Core EC6 (pg 53) - not clear what 'other forms of economic inclusion' refers to. 

Core G4 1 (pg 53) - This could also be difficult to report as C&P systems do not necessarily capture length of time with a supplier, 

but just length of time with a specific contract in place with a supplier. 

Core G4 2 (pg 53) As above this is extremely difficult to report as companies would not necessarily have a full history of every 

supplier it has ever placed an order with. The fact that the disclosures request both short and long term relationships with suppliers 

seems to show a lack of clarity on what parameter is really meaningful. 

Add G4 4 (pg 54) This is very onerous to report as will require an additional role to be created to aggregate such information for the 

whole company. Also each organisation will only use certifications which makes sense to their business, making any comparisons of 

organisations with this information difficult. It is therefore questionable whether the investment required to report on this matches 

the value add of this parameter being reported. 

Core G4 5 As described above we can not disclose the location of suppliers as this will be disclosing information about suppliers 

which they may not wish for us to share. This could potentially lead to legal issues as identifying a suppliers location also provides 

enough information for a suppliers identity to be determined. 



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Core G4 5 & 6 (pg 64) As described previously it can be difficult for companies to determine if dealing with “new” suppliers, or 

existing suppliers bidding for new work. 

Core G4 6 (pg 64) The wording of this indicator is not entirely clear. We would generally screen new suppliers (i.e taking on a new 

contract) for having potential adverse impacts according to our screening criteria. We would not screen existing suppliers unless we 

class them as high risk. Furthermore we would not be able to say if suppliers/other business partners have actual adverse impacts as 

this could be considered libel! 

Core G4 6, 9, 11 & 13 - The breakdown of screening impacts for environment, labour practices, society related and human rights 

may not be the same breakdown used by companies, and there may be additional items that do not fall into these categories. It is 

not clear whether it is beneficial to mandate this breakdown. 

Supply chain disclosure items on pg 66-67 (lines 810-834) are broken down too much - and could be aggregated. As a minimum 

improvement, actions taken to determine 'x' and actions taken as a result of 'x' should be consolidated to one disclosure point, 

making it 5 disclosures instead of 10. For example line 820 and line 822 could be aggregated. However realistically a company is 

likely to aggregate reporting on some of these parameters as it is unrealistic (from an investment & space perspective) to report on 

each item separately. These items are also not referenced which is inconvenient. 

It is not apparent why it is necessary to break down suppliers & partners 'screened', 'having actual and potential adverse impacts' 

and 'number of related grievances' per environment, labour practices, society related performance and human rights. Instead of 12 

indicators, this could be aggregated to 3 (G5, G8, G12 & HR2), (G6, G9, G11 & G13), (G7, G10, HR11 & G14) - each relating to all of 

the afore mentioned subject areas. Otherwise the breakdown becomes meaningless and difficult to follow. 

Grievance indicators G7, G10, G14 (pgs 65, 74 & 87) - The differentiation between human rights and non-human rights related 

grievances is a distinction that can be difficult to apply in practice. Although some complainants articulate their concerns in the 

language of human rights, the vast majority of complaints received relate to operational impacts. 



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Grievance indicators G7, G10, G14 & HR11 are essentially asking for twelve different pieces of information: 1) grievances filed, 2) 

addressed, 3) resolved; 4) held over from a previous reporting period; breakdown of complainants by whether the complaint is 5) 

internal or 6) external or 7) a supplier, with further breakdowns by 8) gender; 9) membership of ‘underrrepresented’ groups; 10) 

unspecified indicator(s) of ‘diversity’; and all of the above broken down by 11) the topic of the grievance and 12) the geographic 

location of the complainant. This level of disclosure is a mini-sustainability report in itself and is not reasonable or useful to expect 

companies to report on at this level. 

Grievance indicators G7, G10, G14 & HR11 - for commercial and legal reasons, reporting on grievances received from suppliers is 

problematic. The indicator is also not clear about reporting boundaries: is a company expected to report only on non-commercial 

grievances, or on all grievances, including commercial? It is not clear why only suppliers are included here and not contractors as 

well. 

Requirements on grievances G7, G10, G14 & HR11 - reporting by gender, ‘underrepresented social groups’ and ‘other indicators of 

diversity’ would be extremely difficult in practice. While gender is theoretically possible, the other two categories are too vague to 

allow consistent responses. In addition, it is important to bear in mind that we may be prohibited in some jurisdictions by data 

protection and anti-discrimination laws from disclosing this kind of data. 

The definition of Grievance Mechanism could be considered a bit loose. Suggest the definition should be tighter: ‘A systematic 

process for receiving and responding to grievances’. 

The definition's reference to The UNGP Effectiveness Principles for grievance mechanisms are quoted incorrectly. The eight 

principles are: legitimate, accessible, predictable, equitable, transparent, rights compatible, based on dialogue and a source of 

learning. 

Retail companies have extremely complicated value chains, which sell tens of thousands of products from thousands of suppliers. 

Mapping the full value chain is often not possible; mapping and reporting would require technical capabilities, personnel, and upper 

management support that do not exist in every company. Further, it would be challenging to map every type of environmental and 

social impact to the value chain and report in a concise manner. For example, a retailer may sell certain products whose production 

is energy-intensive but other products for which material use or waste generation is a more significant consideration than energy 

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use. Plus, depending on the kind of product, the types of impact vary across the stages of the value chain. Finally, companies may 

not be able or willing to disclose details about the new suppliers to protect their competitive interests. 

Screening and assessments will put pressure on costs - while there may be some justification for the Wal Marts of the world to carry 

out such excercises, but for local businesses taking on roles that should be fulfilled by governments, is something that makes 

purpose not very self evident. Done on a voluntary basis, it will bring cost disadvantage, without benefits to shareholders. Many of 

the requirements are simply not do-able 

see answer nr. one 

see comments for question 6. Do you have other general comments related to the Supply Chain Disclosures? 

Some of the detailed spending numbers broken down by new and ongoing suppliers will be difficult to obtain likely. 

Supply chain is definitively in important part. However, it is not mentioned why the supply chain has such a dominance within the 

value chain? 

the content is feasible, but see document for comments on description. 

The Guidelines can be daunting at first glance, which may be problematic as many companies may currently find it challenging to 

report on the scope of their supply chains, and the amount of details sought may deter companies from reporting. It would be 

helpful to have a “scale up” approach for companies that are reporting for the first time and may be overwhelmed by the depth 

sought. Ceres feels that overall the indicators are effective for building supply chain management, though more effective for policy 

rather than performance. We would also recommend an addition to the Guidelines for companies to have suppliers influence their 

own suppliers, thus having a cascade effect across the value chain. 

The inclusion of supply chain indicators addresses important issues absent from the current guidelines. However, many of the 

indicators proposed will be practically impossible for many industries to report at a global level. See comments in the Document 

Review section for some examples. 


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for academic 

purposes 

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Markets & 

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The inclusion of Supply Chain specific indicators in the guidelines is a very possitive and important issue but there is a great 

difference between de depth required for these indicators and disclosures and the depth required for other topics. The guideline 

asks for too information, sometimes very difficult to obtain. Organizations should feel that this information provides value for the 

organization itself. The guidelines should explain the rationale for certain indicators. 

The indicators are too detailed and may not reflect the reality of supply chain management and screening. The reporting should on 

a more general level giving flexibility with regard to the sector (e.g. screening in retail vs. finance) and it should take into account the 

maturity level of supply chain management. Percentage of suppliers may be unfeasible for many companies to report. 

The level of detail is not obtainable for a global company with large and complex supply chains just beginning to work on its supply 

chain practices. If it is required for "in accordance with" status, this will just be more reason to abandon the GRI. 

The level of detail required is too high for several disclosures e.g. number of suppliers, materials sourced, etc. At the same time, 

several terms and requirements remain unclear (see question 1.). The definition of suppliers will have a significant impact on the 

amount of data and the possibility to evaluate the data. The depth of evaluation needs to be defined more precisely. The maximum 

depth of evaluation should be by country and only for first tier suppliers. In addition, some information might be confidential or of 

competitive relevance e.g. reasons for termination of cooperation, data about strategic suppliers, etc. The disclosure requirements 

for the aspects Screening and Assessment as well as Remediation are too detailed and repeatedly requested for each category 

(environment, social etc.). Since this a minimum requirement for reporting “in accordance with” G4 this will lead to redundancies 

and uneconomical efforts. A possible scenario is that companies will not be able to collect such an amount of information. 


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Further comments on this are made e.g. on p.28 (DI 11), p. 29 (DI 12), p.53 (EC6), p.64ff (G4 5ff), p.73ff (G4 8ff), p.79ff (HR 2ff). 

The level of detail required specific to supply chain will drastically increase the level of effort required to prepare our report, and will 

take several years to put in place appropriate data collection systems to ensure proper reporting. Suppliers should be reporting 

their own information; if we report, and they report, indicator values will be double-reported. 

Business 

Northern 

America 

Reporter 

The same comment applies to reporting relaed to our customers, which we are unclear if we also need to incorporate bases on the 

new boundary definition that also incorpoates this unclear concept of "value chain." If our direct customers (who are huge 

companies often larger than us) are within our value chain it will be years, if ever, we can report on them. 

This value chain concept is good in theory if you are developping standards for the Walmarts of the world that truly influence their 

supply chain. For small to medium size companies this makes the GRI standards less relvent to managing their impacts. 



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The level of quantitative information required for Supply Chain disclosures will deter organizations from disclosing such information 

Public disclosure of Supply Chain aspects, especially as those mandated in the DMA and those relating to numerical information on 

supply chain can affect the competitiveness of an organization, and may be controversial for organizations to disclose. Companies 

may take such views as the classification levels mandated by the G4 Guidelines, which goes into significant depth: 

§ The types of materials, products and services provided by suppliers that are used for the organization’s primary brands, products 

and/or services 

§ Types of suppliers 

§ Location of suppliers by country and/or region. 


Report Reader 

Another factor is that companies tend to have non-disclosure agreements with their suppliers, which is proprietary and confidential 

information that cannot be publicly disclosed. 

The level of quantitative information required for Supply Chain disclosures will deter organizations from disclosing such information: 

- Public disclosure of Supply Chain aspects, especially as those mandated in the DMA and those relating to numerical information on 




• The types of materials, products and services provided by suppliers that are used for the organization’s primary brands, products 


• Types of suppliers 

• Location of suppliers by country and/or region. 



The level of quantitative information required for Supply Chain disclosures will deter organizations from disclosing such 

information:- 




a) The types of materials, products and services provided by suppliers that are used for the organization’s primary brands, products 

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b) Types of suppliers 

c) Location of suppliers by country and/or region. 




informations 

The new indicators can appear to be repetitive in the report. GRI could considered to subsume the different aspects (Human Rights, 

Labor Practices, Society and Environ-ment) under each supply chain monitoring action (screening, assessment, remediation). 

Screening, Assessment and Remediation should be described in more detail. Reporting organizations should be required to specify 

which tier of suppliers is addressed with each supply chain monitoring action and demonstrate alignment with/communicate gaps 

to the risks identified in the reporting organizations supply chains. The feedback from our clients was that they would probably not 

report on their supply chain since it would be too resource intensive and complex to collect data. 

The new supply-chain indicators ask for a level of detail that falls out of the general material scope for the average company and 

substantially increases the amount of hours and resources necessary for the data collection and validation process. 

The proposed Economic Indicators Core G4 1, Core G4 2, and Core G4 3 in regards to Supply Chain are not relevant measures for 

corporation economic performance and should not be included in the Guidelines. These Indicators report spending on long-term 

suppliers (Core G4 1), percentage of new suppliers (Core G4 2), and time taken to pay suppliers (Core G4 3), none of which is an 

indication of a corporation's economic performance. 


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In addition, it may not be currently feasible and/or cost effective for all corporations to collect the supply chain information required 

to report on these Indicators. Some suppliers may not be sophisticated enough and/or the effort involved to obtain the data may 

outweigh the value of the information. 

The proposed level of reporting for supply chain-specific Indicators is not feasible and goes well beyond G3 / G3.1. The detail 

required, even at the first-level of suppliers, is already extraordinary and will take years for implementation by companies. 

Business 

Northern 

America 

Reporter 

It is not helpful that the 11 new indicators G4.5 through to G4.14, as well as HR2 and HR11, are clones of each other. This number 

of indicators requesting “broken down” data is unnecessary and the text duplication could be avoided and simplified by creating 

one single indicator, focused on supplier management including screening, impacts and grievance mechanisms. It is also noted that 

disclosure of supplier issues and locations is a request for information that may well be sensitive in terms of competition and 

relationships between suppliers. 



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In their current form, the 11 indicators request a significant volume of data by nature of impact, locations, responding actions etc. 

Beyond creating a reporting burden for companies while adding relatively little value in terms of insight into performance, it is not 

conveyed how GRI stakeholders will benefit from this level of granularity. It is suggested that the disclosure guidance is reworded to 

introduce a stronger focus on addressing the most significant supply chain impacts. The draft G4.7, G4.10 and HR 11 indicators – 

related to grievance mechanisms – present some significant additional challenges given that reporting on grievances received from 

suppliers at this level of detail can be problematic for commercial and legal reasons. 

The proposed level of reporting goes well beyond G3 / G3.1 and is effectively a step-change. The detail required, even at the firstlevel 

of suppliers, is extraordinary – while it is important to disclose how a company influences its supply chain, individual suppliers 

should provide the specific detail on their own sustainability performance. These proposed disclosures will take years for 

implementation by companies and GRI may well only create a “cottage industry” of data systems that give an impression of risk 

management but does not provide clarity on whether a company has adequate systems in place to sustainably manage supply chain 

issues. 


It is also noticeable that the 11 new indicators G4.5 through to G4.14, as well as HR2 and HR11, are “cut and paste clones” of each 

other. This number of indicators requesting “broken down” data is unnecessary and the text duplication could be avoided and 

simplified by creating one single indicator, focused on supplier management including screening, impacts and grievance 

mechanisms. It is also noted that disclosure of supplier issues and locations is a request for information that may well be sensitive in 

terms of competition and relationships between suppliers. 




introduce a stronger focus on addressing the most significant supply chain impacts. 

The draft G4.7, G4.10 and HR 11 indicators – related to grievance mechanisms – present some significant additional challenges given 

that reporting on grievances received from suppliers at this level of detail can be problematic for commercial and legal reasons. 

The proposed supply chain indicators can result in qualitative data that can easily be misinterpreted and diverts attention from a 

company’s overall supply chain management. G 4.1 and G 4.2 attempt to quantify the stability of a supplier base, but the selection 

of suppliers and maintenance of certain suppliers can be influenced by many factors. These disclosures do not permit distinction of 

companies with an unstable supplier base from companies whose business strategy leads to regional changes in their operations. 

For example, an oil and gas company’s exploration activities can result in relatively rapid country entries and exits. Additionally, 

companies in the oil and gas sector will often have mandatory long-term production sharing contracts with government entities 

with stipulated supplier requirements, which may make a company appear to have very stable supplier/contractor relations. 

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G4.3, which requests time taken to pay suppliers, could result in similarly misleading data. Supplier payment terms vary based on 



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contract terms and regional operating norms. Quantifying this as one global number would not be indicative of a company’s overall 

supplier payment performance. 

Hess also concurs with the following response to this question submitted by IPIECA: 

The proposed level of reporting goes well beyond G3 / G3.1 and is effectively a step-change. The detail required, even at the firstlevel 

of suppliers, is extraordinary – while it is important to disclose how a company influences its supply chain, individual suppliers 

should provide the specific detail on their own sustainability performance. These proposed disclosures will take years for 

implementation by companies and GRI may well only create a “cottage industry” of data systems that give an impression of risk 

management but does not provide clarity on whether a company has adequate systems in place to sustainably manage supply chain 

issues. 

It is also noticeable that the 11 new indicators G4.5 through to G4.14, as well as HR2 and HR11, are “cut and paste clones” of each 

other. This number of indicators requesting “broken down” data is unnecessary and the text duplication could be avoided and 

simplified by creating one single indicator, focused on supplier management including screening, impacts and grievance 

mechanisms. It is also noted that disclosure of supplier issues and locations is a request for information that may well be sensitive 

in terms of competition and relationships between suppliers. 




introduce a stronger focus on addressing the most significant supply chain impacts. 

The draft G4.7, G4.10 and HR 11 indicators – related to grievance mechanisms – present some significant additional challenges given 

that reporting on grievances received from suppliers at this level of detail can be problematic for commercial and legal reasons. 

The relative importance of supply chain as an issue varies between firms and sectors. It would be better to have a separate supply 

chain section. The section should be structured to allow for comment about the importance of supply chain as an issue, to outline 

the approach and to use a selection of appropriate indicators 

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The requirement for reporting on the supply chain puts a heavy burden on the reporting organization. 

For example line 677 onwards on local suppliers (Core EEC 6): what is the expected out come from this? 

Line 696 – Average no of days for payment, this varies from supplier to supplier, country to country- Once again, it is important to 

understand the purpose of reporting this. 

CORE GR6 -Line 760 onwards – reporting demands are very ambitious. Ex. for large multinationals. Where to draw the line? Need 

proper guidance for calibration purpose. If not reports can never be compared. 

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Aspect: screening and assessment 

We appreciated the new focus in the guidelines on the issue of supply chain, in our opinion today one of the main critical issue 

related to sustainable development. 

We believe that the Guideline should provide more details on the concept of “screening” and “assessment”: being current supply 

chain monitoring practices very different (self-assessment using simple questionnaire-check lists, second party audits, third party 

certifications…), the risks is to comply to these requirements with different approach with different level of reliability. 

We suggest including, in the standard disclosure, the request of information of the “nature” of the screening and assessment (eg: 

1st part – declaration - document and / or on site self-assessment; 2nd part assessment; 3rd part assessment and certification 

etc…). 

We believe that in this way we increase the use of reliable techniques to assess the risk at supply chain level. 

The requirement for reporting on supply chain puts a heavy burden on the reporting organisation. The level of detail required is very 

high, what is the expected value and outcome of this? For example, line 696 'average number of days for payment" this varies from 

supplier to supplier, country to country. It is important to understand the purpose of reporting this. Also, for line 760 onwards the 

reporting demands are very ambitious. Where to draw the line? Need proper guidance for calibration purpose. If not, reports can 

never be compared. 

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We appreciated the new focus in the guidelines on the issue of supply chain, in our opinion today one of the main critical issues 

related to sustainable development. However, we believe the Guidelines should provide more details on the concept of "screening" 

and "assessment". We suggest including, in the standard disclosure, the request of information of the "nature" of the screening and 

assessment (e.g. first part- declaration document and/or on-site self-assessment, 2nd part assessment, 3rd part assessment and 

certification etc.) We believe that in this way we increase the use of reliable techniques to assess the risk at supply chain level. 











Mediating 

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Europe 

Consultant 

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Provider 

Report Reader 

We appreciated the new focus in the guidelines on the issue of supply chain, in our opinion today one of the main critical issues 

related to sustainable development. However, we believe the Guidelines should provide more details on the concept of "screening" 

and "assessment". We suggest including, in the standard disclosure, the request of information of the "nature" of the screening and 

assessment (e.g. first part- declaration document and/or on-site self-assessment, 2nd part assessment, 3rd part assessment and 

certification etc.) We believe that in this way we increase the use of reliable techniques to assess the risk at supply chain level. 

The requirement for reporting on the supply chain puts a heavy burden on the reporting organization. 

Mediating 

Institution 

Europe 

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For example line 677 onwards on local suppliers (Core EEC 6): what is the expected out come from this? 

Line 696 – Average no of days for payment, this varies from supplier to supplier, country to country- Once again, it is important to 

understand the purpose of reporting this. 

CORE GR6 -Line 760 onwards – reporting demands are very ambitious. Ex. for large multinationals. Where to draw the line? Need 

proper guidance for calibration purpose. If not reports can never be compared. 

The requirements have increased, and it may suppose a bigger effort to answer all of them: i.eg. G41, G42… In addition, G4.4 seems 

more relevant for a manufacturing company than for a services’ company. 




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The requirements will be hard for large multinational companies to report due to level of detail required. Also businesses which 

have diverse products and services, getting the information for each may take too much time for any business value in going 

through the effort. 

The set of indicators is somewhat effective to measure performance. And it is therefore almost not feasible to report. For large 

companies with multiple suppliers, such detailed disclosure is a big challenge. It will be difficult to align the proposed disclosure with 

the objective to encourage more companies to report on ESG aspects with GRI G4. 

An example for this is indicator DI 12, which requires a description of the supply chain. This would require not only considerable 



Also the disclosure on the procurement practice will be extremely difficult for large companies to report accurately and in a timely 

fashion. 

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Reporter 


It would be useful to focus on the most meaningful indicators (e.g. the percentage of suppliers screened or assessed on 




The set of indicators is somewhat effective to measure performance. But it is not feasible to report. 


For large organizations with multiple suppliers, such detailed disclosure is a big challenge. Also for many SME the disclosure will be 



An example for this is indicator DI 12, which requires a description of the supply chain. This would require not only considerable 



Also the disclosure on the procurement practice will be extremely difficult for large companies to report accurately and in a timely 

fashion. 

It would be useful to focus on the most meaningful indicators (e.g. the percentage of suppliers screened or assessed on 




The supplier disclosures have gone too far and have become a bit ridiculous. To report all of these requirements would necessitate a 

report all on its own. It would also require new resources and systems to be implemented. Companies with large supplier bases that 

consist of large corporate to small enterprises would find it very difficult to report to this level. I suggest that this be relooked and 

simplified to the most critical and reasonable measure. 




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In addition the further breakdown of ‘issues raised’ during the screening of suppliers into categories of location, nature of issue and 

location of issue for each environmental, social, human rights and labour issue is impossible. 

The level of supplier detail is somewhat confusing for me particularly in light of the GRI requirement that each aspect be placed in 

the value chain – that would mean that environmental performance, human rights, labour practices etc should cover customers and 

suppliers by inference? So why is there a whole new set of supplier indicators covering these topics? We could do the same for 

customers then – seeing as they are a major part of any organisations value chain. If these new indicators are to determine the level 

of screening – could they not be collapsed into one indicator for NEW and one for EXISTING suppliers asking all the screening 

questions in one go? It feels very much like we are now running in circles. 

The supply chain indicators should more accurately reflect to actual relationships between the corporation’s mission and its 

relationships with suppliers. To this end, the guidance should seek achievable measurements of supply chain impacts that are 

comparable across and within business sectors. 

The supply chain-specific indicators are very comprehensive, but different industries might have their unique material supply chainspecific 

indicators. For example, for certain industry, lead time and over time might be materials, for some, procurement pricing are. 

For companies deal with labor intensive products, it might be impossible to report all these indicators in an way that they can afford 

the cost and efforts. 

There are few companies with such control over their suppliers and able to obtain so much information as it is required in the new 

G4 Guidelines 

There are some issues hier: It will be very hard to get information from suppliers. Companies will estimate qualitative information, 

as impacts caused by their operations. In my opinion supply chain, as a major element in G4, should still be handled less complete 

than proposed. This should be completed in G5 over 3-4 years. Organizations need time to organize all this information. The step 

between G3 and G4 is to large. It will also be very hard to verify this (I work with assurance of reports!). 

There is a very large amount of information that will need to be collected from the supply chain. Although many of these indicators 

would be preferable to know, it is an enormous amount of data for suppliers and customers to be collecting. If I were a company 

seeking to report on my supply chain, I would be very daunted on how to achieve the guidelines in regards to the supply chain. If 

GRI signposted to organisations such as Sedex (Supplier Ethical Data Exchange) as supply chain mapping tools, I think this would give 

support to companies who are only beginning to report. 

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There is little about the economic sustainability of the suppliers, even if it is one of the most important questions. If a supplier is not 

economically sustainable, it can really endanger the company. An economically stable supplier can grow together with the company, 

and can develop in other aspects of sustainability as well. Long-term cooperations can be strated, safer for the company and the 

supplier. energy on avoiding risks can be invested in ethics, equal opportunities, environmental issues etc. 

there should be linkage between ESG risk in the supply chain to relevant indicator(s) chosen 

Mediating 

Institution 

Europe 

and AB 

members with 

in-depth, 

analytical 

reports that 

highlight 

trends, alert to 

potential risks 

and help to 

prioritise your 

resources. Our 

Data Services 

team can also 

produce 

management 

reports or 

statistical 

analysis that 

can be 

included in 

companies’ 

annual review 

or CSR report. 

Consultant 

Assurance 

Provider 

Mediating 

Institution 

Asia 

Reporter 

Consultant 

There should be more focus on assessing organisational policy and its performance against this policy Business Europe Reporter 

These are certainly effective measures of performance, however measuring and reporting on (all of) them would be very 

cumbersome for many reporting organizations, as obtaining information from suppliers (especially those not bound by formal 

contracts) is an extensive operation, often resulting in incomplete information. We question whether some of the disclosures, for 

example G4.1, 4.2 and 4.3 are really material and may divert reporters away from what is really important. 

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So, in general we believe there are too many disclosures for effective (and concise) reporting. Some indicators are also too 



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complicated to calculate (also because some information may not be available for the entire supply chain). We recommend 

decreasing the number of indicators and focusing only on the main ones. 

These indicators are not effective nor feasible to report, as the G4 draft Glossary specifies that suppliers can be companies 

(obviously small or large) or individual consultants or home workers. Supply chain related indicators (e.g. under Screening and 

Assessment) ask for the percentage of suppliers meeting certain criteria. If there are a few large suppliers, and a large number of 

single-person suppliers, a small "percentage" number might mean almost all of the supplies purchased. And it would often be 

impossible in practical terms to get numeric information on the exact number of all suppliers, if this includes very small contracts. To 

make the definitions and indicators meaninful, percentage information should be changed to proportion of purchase value, or 

suppliers should be changed to significant suppliers (defined as having a high contribution to purchase value). 

They are effective, we don't consider them feasible. For a company that is starting on sustainability practices, to be able to gather all 

that info from their suppliers in just two years seems like a big task. 

Too much detail is being requested. The indicators will be difficult to measure and will be very challenging for companies with 

complex supply chains. 

Also, occupational health and safety concerns are not adequately covered. 

This step overall, however, is a step in the right direction. 

Too much detail is being requested. The indicators will be difficult to measure and will be very challenging for companies with 

complex supply chains. 

Also, occupational health and safety concerns are not adequately covered. 

This step overall, however, is a step in the right direction. 

Mediating 

Institution 

Mediating 

Institution 

Civil Society 

Organization 

Civil Society 

Organization 

Northern 

America 

Latin America 

Northern 

America 

Northern 

America 

too much granularity requested. a handful of core macro-measurements would be more powerful for reporting disclosure. Business Northern 

America 

Consultant 

Reporter 

Consultant 

Report Reader 

Report Reader 

Report Reader 

Reporter 

Vale recognizes that value chain perspective is very important to address sustainability impacts but our suggestion is that the 

sustainability report should focus on how the organization influence sustainable management practices within the supply chain. The 

responsibility of the reporting organization to obtain the data regarding sustainability performance for the entire supply chain may 

be onerous, especially when detailed information is required (location of suppliers, selection and termination, monetary value) what 

will probably require a long period to be established. 

very comprehensive, dichotomy between complex and complicated, many new indicators and greater focus on evaluation. It should 

be more focused on management. 



Very few companies (certainly those that we work with) will be able to access this information within a reasonable time frame. 

We appreciate the request to specify whether or not suppliers are selected based on ESG criteria, but there’s no specification of 

what criteria can be considered ESG. Many companies already claim they apply ESG criteria to their suppliers, while they only 

require ISO 9001, which is a quality standard, not an ESG one. 

More important, the indicators are wide and very comprehensive but in our opinion they are not feasible to report. Some indicators, 

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like energy consumption or pay disparity for example, cannot be extended to suppliers and sub-suppliers: if they are not strategic 

suppliers, collecting data would probably be impossible, and even if collected, data would have assurance problems. It is likely for 

companies to have vendor ratings and periodic audits, and to explain those, but having access to direct information is quite unlikely. 

We believe that in case of big multinational organizations, which may have hundreds or thousands of suppliers in total, the 

gathering of the necessary data may not be practical. Moreover, in many cases, the data required to be disclosed are confidential 

(e.g. cost of certain material category purchased – confidential from competitors). So these data may not be disclosed in the CSR 

report or they will be part of a bigger sum, and not separate, leading to false conclusions. Therefore we propose not be so detailed 

the purchased materials. 






We believe that occupational safety and health should be covered far more effectively within the supply chain indicators. Also, as 

indicated in Q1 above, we believe organisations that use large numbers of suppliers may need a system for rationalising their 

reporting on them that focuses on their most significant risks. 

We consider most of them to be effective measures. Their feasibility to report varies. As an organization we are in the process of 

revising our template for member reporting on responsible supply chain management, and we have attempted to feed the 

proposed indicators into our revised reporting template. The following comments reflect feedback received in this process from 

several member companies and also from some other stakeholders. 

Core G4 1 Spending on suppliers with which long-term agreements exist: 

The definition of long-term agreements should be extended to include verbal agreements in addition to contractual agreements. 

Many small and medium sized companies can have long-term relationships with suppliers without having long-term contractual 

agreements. 

Core G4 3 Time taken to pay suppliers: 

The first part, "report the average number of days taken to pay supplier invoices", requires too much effort to put a system for 

measurement in place compared to the value of the information. We suggest to replace this with the number of days to pay that 

are specified in the organization's standard terms. 

We propose to rephrase the second part, "report the percentage of total payments to suppliers that were made late", to read the 

percentage of payments made on time. Although being the same measure, it seems to be more acceptable to report on for some 

Mediating 

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Mediating 

Institution 

Europe 

Europe 

Consultant 

Report Reader 

Consultant 


Our members 

help 

organisations 

prepare and 

use 


reports 

Mediating 

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Europe 

Report Reader 

Member 

organisations 

of ETI-Norway 

has an 

obligation to 

report annually 

on their supply 

chain practices. 



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companies when it is stated positively 

Core G4 5, Core G4 8, Core HR 2, and Core G4 12 on screening of new suppliers: 

The indicator protocols for these indicators are unclear and have some internal inconsistencies in the text. This is evident when one 

tries to follow the protocol and attempts to determine which reporting elements to break down in terms of location, issues etc. and 

how to do it. 

Core G4 6, Core G4 9, Core G4 11, Core G4 13 on assessment of suppliers and actions taken: 

The indicator protocols are difficult to read and understand. There is a lack of internal consistency in the text. For instance, it says 

"break down the above four disclosures..." when eight disclosures are listed above. 

We consider that some of the proposed supply chain indicators would be unfeasible for the vast majority of the companies in 

Portugal due to the level of information required. Despite the fact that Portuguese companies are dealing,on a daily basis, with cuts 

on the structure costs (consequence of the global economic crisis), companies that are interested to report according to these 

indicators will have to design new methodologies to evaluate suppliers performance which will have an impact on the budget. In 

such times of savings approach, we preview that some companies that usually report according GRI, would not adhere to the G4 

standard. 

We could not find the material need to differentiate between new and old suppliers in indicators such as G4 5 and G4 6 (similarly for 

those in the Labour practice, Human Rights and Society categories). A consolidation of new and old suppliers and a focus instead on 

percentage screened AND percentage having an actual or potential impact could be more insightful. 

We find that no sufficient emphasis has been provided to the importance of supply chains on the impact of organizations’ water 

consumption. 

We could not find the material need to differentiate between new and old suppliers in indicators such as G4 5 and G4 6 (similarly for 

those in the Labour practice, Human Rights and 

Society categories). A consolidation of new and old suppliers and a focus instead on percentage screened AND percentage having an 

actual or potential impact could be more insightful. We find that no sufficient emphasis has been provided to the importance of 

supply chains on the impact of organizations’ water consumption. 

We could not find the material need to differentiate between new and old suppliers in indicators such as G4 5 and G4 6 

(similarly for those in the Labour practice, Human Rights and Society categories). A consolidation of new and old suppliers and 

a focus instead on percentage screened AND percentage having an actual or potential impact could be more insightful. 

We find that no sufficient emphasis has been provided to the importance of supply chains on the impact of organizations’ water 

consumption. 

We have worked closely with companies that are on the leading edge of supply chain sustainability management. They still struggle 

with how best to manage supplier risks and -- even more -- how to measure progress. Any specific indicators at this point are 

premature. Reporting should focus on how the companies manage supply chain risks and allow them to devise their own indicators 

-- for a few more years at least, while these programs mature. 

We question whether a number of the specific indicators are necessary. For example with regards to the impact of the suppliers on 

the environment, it is not clear how the information of the percentage of the impact is useful. Similarly how would the information 

pertaining to the number of women and minority groups be useful? 

Mediating 

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Markets & 

Information 

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Financial 

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Financial 

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America 

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Data provider 

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While we agree with the increased focus on supply chain, we recommend that G4 factor the complexity of supply chain issues into 

the guidance. Supply chain is an emerging area, and GRI should allow companies to increase disclosure over time. 

Mediating 

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Northern 

America 

Report Reader 

Research 

Better definition, proven relevance, and focus are needed throughout the supply chain indicators. We strongly suggest that GRI 

reconsider the requests on supply chain and focus on those issues that companies can report on and that are core to sustainability. 

EPRI is willing to work with GRI to improve the supply chain section and provide in-depth comments. 

Yes. Nevertheless there seems to be multiple disclosure requirements combined into one indicator, whereas it is best practice to 

ensure that an indicator only measures a single data point. Hence the following indicators need to be split up into separate 

indicators or else the indicator wording needs to be revised, and the indicator protocols developed for clarity. For example, 

indicator G4 3 asks for two disclosure points on line 696 and 697; G4 5 asks for three different percentage values to be calculated on 

lines 744, 751 and 753; G4 6 asks for multiple percentages on lines 763, 769. 777 and 780; and EC6 ask for three percentages on 

lines 677, 680 and 682. 

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Asia 

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Assurance 

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The other indicators related to the aspect screening and assessment should be reviewed for the same reasons. (G48, G49, HR2, 

G411, G412, G413) 



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- I don't think some of the new questions will help to measure performance in relation to the supply chain, because if a company 

starts to monitor some of the indicators proposed, it will cost more to implement this process than the fair price of the service or 

product and companies will transfer this premium to its consumers or will stop reporting it. 

- some of the indicators are not feasible for large companies to report for all its supply chain. May be a focus on the most significant 

would be more feasible (for example G4 2) 

- There is no guidance regarding the selection. 

- Companies do not have the required depth of information regarding supply chains. 

- An organization should not be forced to tell fourth or fifth tier on how to operate. An organization should have binding contracts 

with their suppliers and expect them to have similar contracts with their suppliers. 

- It is questioned whether an organization would actually create an unfavorable situation by disclosing information about their 

suppliers. 

- Competitiveness reasons might obstruct transparent reporting on suppliers. 

- Question whether large organizations are equipped to comply with G4. 

- Unclear situation if a company is part of another company’s supply chain 

- It is time that organizations define boundaries and explain to readers why some aspects are not reported upon. Not everything 

should be reported upon, there must also be aspects where an organization is allowed to not report upon. 

- An organization cannot be expected to report on all suppliers, but only on core. A company should not be expected to be a 

‘Weltverbesserer’. 

Again, the emphasis is a lot on procurement indicators without including downstream issues. The section is very broad, and its 

architecture is not quite organised and structured in a logical way. a Sequential approach might be more useful for easier 

comprehension, (sort of Life cycle of a product/service framework) 

Almost no one is collecting this data. 

As per above 

Comment 1: The level of quantitative information required for Supply Chain disclosures will deter organizations from disclosing such 

information 










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Economic - Yes; 

Environmental - Not fisible; 

Social - Not fisible (Supplier's access would be limited, where the issue of non compliance arises. Companies will avoid these checks, 

where supplier has a bargaining power. 

effective yes, but not feasible to report 


Institution 


Mediating 

Institution 

Latin America 

Report Reader 

researcher on 


topics 

Report Reader 

academic 

Report Reader 

academic 

Effective yes, feasible no 

Mediating 

Institution 

Latin America 

Effective yes, feasible no. 

Mediating Latin America 

Institution 

effective yes, feasible no. Business Latin America Reporter 

Effective yes, feasible no. Business Latin America Reporter 

effective yes, feasible, no. 

Feasible to report - it is tough for many organisations to venture into the supply chain related data gathering process. Thus it will be 

tough for most organisations to report for these indicators 

For large companies, it is virtually impossible to report on all suppliers. A great number of suppliers and local specificities (cultural or 

legal, for example) may result on difficulties for a reporter to acquire some data from them. 





For so many kind of supplier performance indicators it will be very difficult obtain reliable information and complete the assurance 

process of the data. 

Mediating 

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academic 


Report Reader 


Report Reader 


Financial 

Markets & 

Information 

Users 

Latin America Reporter 




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G4 2- feasible but not effective 

G4 4- Effective but not feasible 

G4 7- make it more detailed 

G4 12, 13, 14- Neither effective nor feasible, hard to understand what it is, too vague 





























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Mediating 

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Provider 

I am not sure they are feasible to report, I fear they are too demanding. Business Europe Reporter 

I think that the propostion extends the levels of suppliers and our focus should be the suppliers that are directly related to the core 

business of the organization. 

I think the indicators will be difficult to measure and will be very challenging for companies with complex supply chains. But I do 

believe the approach is a general step in the right direction. 


Report Reader 

Business Northern Report Reader 

America 



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I think this will be unwieldy and not terribly informative - we should be focusing on specific elements of our supply chain and using Business Northern Reporter 

common references to determine if they have impacts 

America 

I'm not sure of the value of Core G42 (% of suppliers with which order were placed for the first time during the reporting period). Business Northern Reporter 

We are trying to build capacity in local communities and that means many long term commitments with local suppliers - why would 

companies get penalized for building that sort of long term capacity? 

America 

In large size or MNE cases, SC specifc indicators are effective. I find inclusion of SC as a key element in G4 is more than good. 

However related disclosures (and SC included reporting) make reporting attached to 3rd party (supplier) committment. Bu reporting 

is a committment of the company. What I mean is, reporting companies will need supplier performance disclosures more as a result 

of G4. This can result with more reporters in terms of supplier companies to provide information to their customers, but also with 

less reporters due to the lack of SC information. On the other hand for SC specific indicators, it is a de facto obligation to run 

Mediating 

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Asia 

Consultant 

Report Reader 

GRI Regional 

Data 

Partnership 

detailed supplier audit which is financially or operationally impossible for most SMEs. 

It could be improved and simplified by focusing on significant suppliers. 

Mediating 

Institution 

Northern 

America 

Reporter 

Consultant 

It is very difficult to have control on supply chain activities. Disclosure on the same may not be relevant for the organisation. Business Asia Reporter 

it's unclear to me why to disclose the total number of suppliers. For internal reasons (to identify all suppliers it's a good excercise) 

but for the report readers: what's the benefit? 

Mediating 

Institution 

Europe 

Assurance 

Provider 

Many indicators don't present any more the expression 'significant suppliers'. The indicators should focus on the most material or 

most critical suppliers. 

It is difficult to understan some of the indicators as well as the value of the additional indicators. 

All supply chain indicators should be reviewed and reclassified from core to additional. 


Report Reader 










Many of them are not feasible to report. The new information requested on supply chain to the companies are really advanced and 

detailed and at this moment I dont feel that many companies have management tools to be able to collect all this information. Core 

G4 9?? Core G4 11?? ore G4 13?? Not feasible to report. 

Measures such as payment terms are hard to define, will vary widely across firms and suppliers and countries. The guidelines are 

asking for too much detail, and it's not clear for what purpose. 

Mediating 

Institution 

Europe 

Report Reader 


condition of 

membership 


Mediating 

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Report Reader 

researcher and 

educator 



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Missing performance indicators in all areas 

missing performance indicators in all areas 

Civil Society 

Organization 

Mediating 

Institution 

Latin America 

Latin America 

Reporter 

Report Reader 

Academic 

research 

missing performance indicators in all areas Business Latin America Reporter 

missing performance indicators in all areas 


Institution 

missing performance indicators in all areas Business Latin America Reporter 

missing performance indicators on all areas Business Latin America Reporter 

Most companies, even the larger companies who have the resource and have been publishing a GRI based report for some time, will 

find the supply chain linked disclosure elements extensive, expensive to assess and find it premature to even start looking at some 

of the indicators. And many of the new indicators on supply chain are marked CORE. There are issues in adopting this kind of 

directive data-intensive approach. It ignores the fundamental nature of deep supply chains and complexity in assessing them. Some 

of these are a) Multi layered supply chain with complex dependencies of local economy and livelihoods b) Influence is sometimes 

dependent on the direct revenue contribution of business relationship with the supplier. c) Language and diversity barriers - 

communicating ESG is challenging with many of the local suppliers (reporting organizations can but only do this progressively). And 

moreover companies should adopt a non-enforcing enabler approach in their supply chain engagement – especially in economies 

and countries where a uni-dimensional approach on ESG aspects can sometimes go against the basic human rights (livelihood and 

humanitarian) principles in the absence of alternatives coming from fundamental and systemic changes in the local economy. The 

GRI G4 framework, like its predecessor GRI3.1, unfortunately seems to advance this unilateral, data intensive, and compliance 

focused approach to supply chain engagement. 

The reporting framework also seems to assume a certain kind of ‘global organisation’ and supply chain engagement and maturity 

context. For a large global multinational based in a developed economy/region, their supply chain (Figure 1) is primarily with a wide 

range of suppliers in developing economies and to a smaller extent in the home region (developed economies). Due to the relative 

scale (buying power) and the longer duration/process in the development of their global supply chain footprint, their global supply 

chain can be expected to be more mature and geographically dispersed but not necessarily deep/multi-tiered. This presents a 

unique set of supply chain opportunities as compared to a global or large company based out of a developing economy with a 

nascent supply chain engagement (Figure 2). It is important to recognize this when setting guidelines for reporting boundaries (and 

their value/supply chains) and not ignore the history, national/regional context and aspects of control/influence with their supply 

chain. The G4 reporting framework does not provide space for organizations to explore and explain this. 

Most companies, even the larger companies who have the resource and have been publishing a GRI based report for some time, will 

find the supply chain linked disclosure elements extensive, expensive to assess and find it premature to even start looking at some 

of the indicators. And many of the new indicators on supply chain are marked CORE. There are issues in adopting this kind of 





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directive data-intensive approach. It ignores the fundamental nature of deep supply chains and complexity in assessing them. Some 

of these are a) Multi layered supply chain with complex dependencies of local economy and livelihoods b) Influence is sometimes 

dependent on the direct revenue contribution of business relationship with the supplier. c) Language and diversity barriers - 

communicating ESG is challenging with many of the local suppliers (reporting organizations can but only do this progressively). And 

moreover companies should adopt a non-enforcing enabler approach in their supply chain engagement – especially in economies 




focused approach to supply chain engagement. The reporting framework also seems to assume a certain kind of ‘global 

organisation’ and supply chain engagement and maturity context. For a large global multinational based in a developed 

economy/region, their supply chain is primarily with a wide range of suppliers in developing economies and to a smaller extent in 

the home region (developed economies). Due to the relative scale (buying power) and the longer duration/process in the 

development of their global supply chain footprint, their global supply chain can be expected to be more mature and geographically 

dispersed but not necessarily deep/multi-tiered. This presents a unique set of supply chain opportunities as compared to a global or 

large company based out of a developing economy with a nascent supply chain engagement. It is important to recognize this when 

setting guidelines for reporting boundaries (and their value/supply chains) and not ignore the history, national/regional context and 



Most companies, even the larger companies who have the resource and have been publishing a GRI based report for some 

time, will find the supply chain linked disclosure elements extensive, expensive to assess and find it premature to even start 

looking at some of the indicators. And many of the new indicators on supply chain are marked CORE. There are issues in 

adopting this kind of directive data-intensive approach. It ignores the fundamental nature of deep supply chains and complexity 

in assessing them. Some of these are a) Multi layered supply chain with complex dependencies of local economy and 

livelihoods b) Influence is sometimes dependent on the direct revenue contribution of business relationship with the supplier. c) 

Language and diversity barriers - communicating ESG is challenging with many of the local suppliers (reporting organizations 

can but only do this progressively). And moreover companies should adopt a non-enforcing enabler approach in their supply 

chain engagement – especially in economies and countries where a uni-dimensional approach on ESG aspects can 

sometimes go against the basic human rights (livelihood and humanitarian) principles in the absence of alternatives coming 




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from fundamental and systemic changes in the local economy. The GRI G4 framework, like its predecessor GRI3.1, 

unfortunately seems to advance this unilateral, data intensive, and compliance focused approach to supply chain engagement. 

The reporting framework also seems to assume a certain kind of ‘global organisation’ and supply chain engagement and 

maturity context. For a large global multinational based in a developed economy/region, their supply chain (Figure 1) is 

primarily with a wide range of suppliers in developing economies and to a smaller extent in the home region (developed 

economies). Due to the relative scale (buying power) and the longer duration/process in the development of their global supply 

chain footprint, their global supply chain can be expected to be more mature and geographically dispersed but not necessarily 

deep/multi-tiered. This presents a unique set of supply chain opportunities as compared to a global or large company based out 

of a developing economy with a nascent supply chain engagement (Figure 2). It is important to recognize this when setting 

guidelines for reporting boundaries (and their value/supply chains) and not ignore the history, national/regional context and 



New supply chain and boundary can lead to non-accountable, non-verifiable reports 

Organizations may resist from disclosing information given the level of quantitative information required for Supply Chain 

disclosures. Public disclosure of Supply Chain aspects, especially as those mandated in the DMA and those relating to numerical 

information on supply chain can impact the competitiveness of an organization, and may not be beneficial for organizations to 

disclose. Companies may be hesitant as the classification levels mandated by the G4 Guidelines go into significant depth such as: 


Reporter 

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Another element to notice is that Companies tend to have non-disclosure agreements with their suppliers, which is proprietary and 

confidential information that cannot be publicly disclosed. 

Screening and assessments will mean additional costs and bring about cost disadvantage without benefits to shareholders 

Quantitative information (percentage of suppliers) asked for are not always relevant and/or interpretable. Suggestion to focus more 

on transparency of supply and trade chains, identification of high-risk suppliers/countries/value chains and improvement of 

working, human rights and environmental conditions (in indicators / DMAs) than on compilation of numbers that cannot be properly 

assessed and compared. 

Financial 

Markets & 

Information 

Users 

Europe 

Report Reader 

Some are outside of scope of influence and difficult to hold the supplier accountable for, gain data for, or gain assurance of. Business Oceania Reporter 

The culture of companies in other countries were not taken into consideration. Business Latin America Reporter 

The document is not very easy to read as it is. Economic aspects: why the amphesis on local suppliers? Is not a generic indicator, 

centainly not for multinational companies or companies that have to import their resources. 

The G4 1, 2, aren´t effective. That is a sustainability report, so it must focus on sustainable issues. Those indicators are more 

applyable for companies with open capital, so they must account their performance to their shareholders. 

Or, at lest, it could be changed as additional indicators, rather than "core". 

The importance of suppliers and impact various indistruies can have on their suppliers varies greatly. Too much emphasis on 

suppliers in the financil industry may not make sense. 

The indicators are over prescriptive. It is better to have principle based disclosure. 





- The types of materials, products and services provided by suppliers that are used for the organization’s primary brands, products 


- Types of suppliers 

- Location of suppliers by country and/or region. 

Mediating 

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preparer. 

Current 

Academic 

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•The types of materials, products and services provided by suppliers that are used for the organization’s primary brands, products 


•Types of suppliers 



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•Location of suppliers by country and/or region. 




information:- Public disclosure of Supply Chain aspects, especially as those mandated in the DMA and those relating to numerical 

information on supply chain can affect the competitiveness of an organization, and may be controversial for organizations to 

disclose. Companies may take such views as the classification levels mandated by the G4 Guidelines, which goes into significant 

depth: a) The types of materials, products and services provided by suppliers that are used for the organization’s primary brands, 

products and/or services b) Types of suppliers c) Location of suppliers by country and/or region. Another factor is that companies 

tend to have non-disclosure agreements with their suppliers, which is proprietary and confidential information that cannot be 

publicly disclosed. 


















information:- 



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Screening and assessments will impose costs and bring about cost disadvantage without benefits to shareholders 


information:- 













information:- 













information:- 







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information:- 








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information:- 













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information:- 


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The same as explained in paragraph No1, supply chain is the complete chain so the indicators, should explain the impact of the 

complete process (as for example, life cycle assesment) 

There is no guidance regarding the selection. 

Mediating 

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Latin America 

Reporter 

Consultant 

Assurance 

Provider 


Companies do not have the required depth of information regarding supply chains. 

An organization should not be forced to tell fourth or fifth tier on how to operate. An organization should have binding contracts 


It is questioned whether an organization would actually create an unfavorable situation by disclosing information about their 

suppliers. 

Competitiveness reasons might obstruct transparent reporting on suppliers. 

Question whether large organizations are equipped to comply with G4. 

Unclear situation if a company is part of another company’s supply chain 

It is time that organizations define boundaries and explain to readers why some aspects are not reported upon. Not everything 


An organization cannot be expected to report on all suppliers, but only on core. 

There was little thought on the aspect of companies' culture in Brazil 

Civil Society 

Organization 

Latin America 

Reporter 

There’s little thought towards the aspect of culture of companies in Brazil 

Civil Society 

Organization 

Latin America 

Reporter 


Mediating 

Institution 

Latin America 

Report Reader 

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Mediating Latin America Report Reader 

Institution 

student 

There’s little thought towards the aspect of culture of companies in Brazil Business Latin America Reporter 

To complicated, potentially putting companies 'off' reporting according to the GRI. 

Too much detail 

Too much information creates confusion. 

Also, I believe there should be difference between small suppliers and large suppliers with the information required. 

It is illogical to request detailed information on every small supplier 

Very difficult to gather this data. 











While we do appreciate the importance of the supply chain, the proposed indicators are too burdensome. They are not clear and 

are not all in one place. It is difficult to identify which indicators are of upmost importance. In addition, some of the indicators ask 

for things that are beyond our control. 

Yes to effective measures of performance. However there is need to strengthen the guidance on linking materiality to supply chain 

reporting. Strengthen the link/gudiance on value chain mapping, risk assessment and supply chain reporting so that it is apparent 

that expected disclosures/indicators do not relate to entire supply chain base but where impacts are material. 

Mediating 

Institution 

Mediating 

Institution 

Africa 

Asia 

Consultant 

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Reporter 

Consultant 

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Provider 

Report Reader 


Academic 

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Mediating 

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Europe 

Europe 

Europe 

Northern 

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G4- 4 as stated may not be feasible to report on. getting the information for each type of material, product or service and for each 

applicable economic, social or environmental standard may be onerous. 

Feasibility to report- availability and reliability of data of supplier performance may prove to be a challenge. Such extensive 

disclosures on suppliers may present entry barriers to organizations that do not have reliable systems to collate supplier 

performance data. Alternative is to lessen the focus on indicators and more on management approaches aimed at influencing 

positive environmental and social performance by suppliers. 

§ There is no guidance regarding the selection. 


§ Companies do not have the required depth of information regarding supply chains. 

§ An organization should not be forced to tell fourth or fifth tier on how to operate. An organization should have binding contracts 


§ It is questioned whether an organization would actually create an unfavorable situation by disclosing information about their 

suppliers. 

§ Competitiveness reasons might obstruct transparent reporting on suppliers. 

§ Question whether large organizations are equipped to comply with G4. 

§ Unclear situation if a company is part of another company’s supply chain 

§ It is time that organizations define boundaries and explain to readers why some aspects are not reported upon. Not everything 


§ An organization cannot be expected to report on all suppliers, but only on core. A company should not be expected to be a 

‘Weltverbesserer’. 



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Q3) Do you consider the proposed disclosures related to supply chain appropriate and/or complete? 

Yes 




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further 

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• As stated above, the proposed disclosure on the supply chain is too complex and extensive without a clear benefit for the reader 

(See “Specific Questions” – “Supply Chain” – “Question 2” above). 








DI 12 2.a. see. Commentary to ADD G4 4 (70.000 product groups/families) 

2.b. types of suppliers: GRI new definition or a definition e.g. by SAM(DJSI): key/strategic/single source/high spend – an alignment 

would be here valuable On one hand types like manufacturers or wholesalers might be interesting, but how do we categorize as 

company the relevance/importance of a supplier to the company (key, strategic etc.) 

2. c. normally one goes by location with regard to country and not specific zones. We cannot see a value e.g. for our company. 

• ERM supports the addition of supply-chain specific disclosures. However, there is significant overlap between disclosure 

categories. ERM suggests that GRI include a new indicator category just for supply chain to streamline some of these disclosures. 

Mediating 

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• The supply chain disclosures referenced in the Disclosure on Management Approach section do not belong in that section (lines 

581-593). 

We suggest: that the GRI reposition these disclosures as individual indicators or integrate them into Disclosure DI 12. 

• The “additional” DMA disclosures under the new GRI Aspect of “Procurement” may be better addressed as individual indicators 

OR left to the discretion of companies that have determined procurement to be a material issue and are thus applying the DMA 

Disclosure requirements 1-4. 

Mediating 

Institution 

Northern 

America 

Reporter 

Consultant 

Report Reader 

• The “additional” DMA disclosures under the GRI Aspect of “Employment” (lines 809-852) may be better addressed as individual 

indicators OR otherwise grouped under Disclosure DI 12. 

• The actual disclosures under each of the new supply chain indicators for the Screening and Assessment and Remediation Aspects 

in the Environment, Labor, Human Rights, and Society categories are exceedingly detailed and require numerous calculations and 

parsing of supply chain data. Given that (1) many companies are only just embarking on an investigation into their supply-chain 

impacts, and (2) “in accordance” reporting to these proposed G4 indicators represents a tremendous new investment in data 

collection systems, the level of detail and specificity required by these disclosures will preclude many from even attempting to 

gather, much less report on, supply chain data. 

We suggest: that the GRI scale back the specificity, detail, and numerous criteria and sub-criteria that are called for in the newly 

proposed indicators G4 5, G4 6, G4 7, G4 8, G4 9, G4 10, G4 12, G4 13, and G4 14. We also suggest that these indicators be 

condensed into one set of Screening and Assessment and Remediation indicators rather than being included in each main GRI 

category. 

•Deutsche Bank feels that the proposed disclosure on supply chain details is generally too complex and extensive. 

A critical change in the G4 is removing the focus on "significant" suppliers so that the disclosures relate to all suppliers. This 

proposed change would significantly increase the burden of preparing a GRI report and would actually reduce the value of the 

report by removing the ability to focus on significant suppliers. While we caution against restricting all report content to material 

issues, this proposed change raises exactly the opposite concern: that the need to address ALL suppliers would reduce the focus on 

significant and/or priority suppliers. Many large companies (which make up the vast majority of reporters) have tens of thousands 

of direct suppliers and would not be able to review all of its suppliers simultaneously. Indeed, the UN Guiding Principles on Business 

and Human Rights explicitly state that companies with large numbers of suppliers cannot be expected to assess all suppliers 

simultaneously and should prioritize their engagement to maximize their impact. 

Again, the provisions related to child labour are quite narrow, and does not allow a business to consider the solutions beyond 

addressing the child labour problem that is at hand. It does not lead them to think about how the root causes to child labour could 

be addressed. So for instance there could be issues related to minimum living wage for adults that is one of the issues, or perhaps 

the lack of educational opportunities in the communities. Those aspects should be part of the indicators as well. 

Financial 

Markets & 

Information 

Users 

Mediating 

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Mediating 

Institution 

Europe 

Northern 

America 

Europe 

Reporter 

Reporter 

Industry 

Association 

Consultant 

Advising 

agency on how 

to integrate 

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As far as sub-suppliers are concerned, there should be a specific section, given their specificity in some sectors, and companies 

should disclose on third parties audits, for example led by NGOs, if any. 

We believe that the Guideline should provide more details on the concept of “screening” and “assessment”: being current supply 

chain monitoring practices very different (self-assessment using simple questionnaire-check lists, second party audits, third party 

certifications…), the risks is to comply to these requirements with different approach with different level of reliability. 

We suggest including, in the standard disclosure, the request of information of the “nature” of the screening and assessment (eg: 

1st part – declaration - document and / or on site self-assessment; 2nd part assessment; 3rd part assessment and certification etc…). 

Financial 

Markets & 

Information 

Users 

Europe 

work and 

reporting 

Reporter 

Report Reader 

As stated above, the proposed disclosure on the supply chain is too complex and extensive without a clear benefit for the reader Business Europe Reporter 

(See “Specific Questions” – “Supply Chain” – “Question 2”). 

As stated above, the proposed disclosure on the supply chain is too complex and extensive without a clear benefit for the reader. Business Europe Reporter 

As we said in question 2, disclosures related to supply chain are too depth. We think the guidelines should reflect material issues Business Europe Reporter 

related to supply chain that applies to a wide range of organizations and to use the sector supplement to include more specific 

issues. 

Aspect: screening and assessment 

Mediating 

Institution 

Europe 

Assurance 

Provider 

We appreciated the new focus in the guidelines on the issue of supply chain, in our opinion today one of the main critical issue 

related to sustainable development. 

We believe that in this way we increase the use of reliable techniques to assess the risk at supply chain level. 

DI 11, bullet #3 – this point is asking for three specific pieces of information that as currently written could result in reporters only 

partially reporting against these requirements. It is recommended that this disclosure point is broken into its sub components. 

It may be inappropriate and commercially sensitive for reporters to provide information on the change in relationships with 

suppliers including selection and termination and hence, it is recommended that this sub component of the disclosure is removed. 

Mediating 

Institution 

Asia 

Consultant 

Assurance 

Provider 

Lines 581 – 593 – The supply chain disclosures on management approach listed on lines 581 – 593 can be moved to the standard 

disclosure section. The reason for this is that these disclosures on management approach are general in nature and would not be 

repeated for each material aspect, furthermore they closely relate to DI11 & DL12. 

The additional disclosures on management approach items for each category e.g. those listed on lines 809 – 852 under the 

Employment DMA should be numbered items for ease of audit and assurance, as well as for report preparers to navigate the 

guidance. 



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DI 7 p. 27 line 89 Significant impacts - Is the intent to describe the entire value chain here? How will this link to supply chain in DI 12 

(p. 29 line 99) and DI24 line 137 on how the value chain was determined? 

Business 

Northern 

America 

Reporter 

DI 11 p. 28 line 96-97– significant changes during reporting period in location of and changes in relationship with suppliers – again 

we are concerned this scope is too broad and would rather see this limited to “significant” suppliers only. 

Disclosures could be enhanced to address the intent of the indicator and contribute to the overall goal of more focused and material 

reporting. 

Disclosures could be enhanced to address the intent of the indicator and contribute to the overall goal of more focused and material 

reporting. 

E.g. CORE G4 3 was not included in G3 as it was considered irrelevant – why is it included in G4 as it reflects only the agreed terms of 

payment. The indicators should be revised with regard to materiality and supply chain management in practice. 

El tema de proveedores y contratistas es muy importante como para ser dejados en la forma precaria propuesta. Deberían estar 

considerados en un capítulo distinto, específico sobre ellos, ya que de la forma actual se abordan de manera desagregada (sólo en 

indicadores EC6 y HR2.) 

G4 3 – Time taken to pay suppliers 

Comment: this does not seem appropriate for a GRI disclosure. 

Generally G4 provides a significant advance through the greater focus on the supply chain and associated indicators. But, some of 

the Profile Disclosure Items in part 1 are requesting a lot of data that on the one hand is very challenging to map and for some 

companies maye be business critical and commercially sensitive, and on the other hand is not very useful to the reader. For 

example, DI11 and DI12 are far too detailed. 

Mediating 

Institution 

Northern 

America 

Report Reader 

Research 


America Report Reader 


Reporter 

Institution 

Consultant 

Assurance 

Provider 

Report Reader 


Business 

Mediating 

Institution 

Northern 

America 

Europe 

Reporter 

Consultant 

Assurance 

Provider 

Report Reader 

Whilst recognising the desire for consistency across the categories, the language of environment indicator G4 6 (lines 756-765) is 

inaccurate as all suppliers are likely to have an adverse impact on the environment one way or another. We are operating in an era 

of environmental deterioration, therefore it is more the degree of adverse impact rather than if there is one. Two potential 

solutions: add 'significant' to 'actual or potential adverse impacts on the environment', or another approach would be to ensure that 

through supplier screening the organisation understands what the most significant environmental impacts of the supplier are and 

that the reporting organisation is required to report on the contract clauses/collaborative projects it has put in place to encourage 

performance improvements at the supplier in relation to these impacts. 

Generally G4 provides a significant advance through the greater focus on the supply chain and associated indicators. But, some of 

the Profile Disclosure Items in part 1 are requesting a lot of data that on the one hand is very challenging to map and for some 

companies maye be business critical and commercially sensitive, and on the other hand is not very useful to the reader. For 

example, DI11 and DI12 is far too detailed. 

Mediating 

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Europe 

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Whilst recognising the desire for consistency across the categories, the language of environment indicator G4 6 (lines 756-765) is 



solutions: add 'significant' to 'actual or potential adverse impacts on the environment', or another approach would be to ensure that 

through supplier screening the organisation understands what the most significant environmental impacts of the supplier are and 

that the reporting organisation is required to report on the contract clauses/collaborative projects it has put in place to encourage 


Generally G4 provides a significant advance through the greater focus on the supply chain and associated indicators. 

But, some of the Profile Disclosure Items in part 1 are requesting a lot of data that one the one hand is very challenging to map and 

for some companies may be business critical, and on the other hand is not very useful for the reader. For example DI11 and DI12 is 

far to detailed 

Mediating 

Institution 

Europe 

Consultant 

Whilst recognizing the desire for consistency across the categories, the language of environment Indicator g4 6 (lines 756-765) is 



solutions: add ‘significant’ to ‘actual or potential adverse impacts on the environment’, or another approach would be to ensure that 

through supplier screening the organization understands what the most significant environmental impacts of the supplier are and 

that the reporting organization is required to report on the contract clauses/collaborative projects it has put in place to encourage 


Hess concurs with the following response to this question submitted by IPIECA: 

Business 

Northern 

America 

Reporter 

See above. It is not clear what the purpose is of the detailed data disclosures, and why similar indicators are repeated for 

environment, labour practices, human rights etc. As noted later, the separation into G4.7, G4.10 and HR 11 indicators – related to 

grievance mechanisms - are particularly problematic since the distinction between ‘human rights related grievances’ and ‘nonhuman 

rights related grievances’ is often extremely difficult to apply in practice. 

Apart from the indicators, the added value and purpose of the extensive broken down information in standard disclosure D 12 



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(page 29) is unclear. Added to this, the long un-referenced list of DMA supply chain disclosure items on pg 66-67 is also repetitive 

and broken down too much This information could be easily aggregated as it is unlikely that a reporting organization will have the 

resources or capacity to report on each item separately. 

As mentioned in response to 2 above, there is also no clear merit to having three separate indicators for screening, assessment and 

grievance mechanisms and no explanation in the proposed guidance related to this decision. 

I consider some of the proposed disclosures superfluous. In particular, I think the information on suppliers’ location, nature of issues 

and location of issues to be excessive, except special indicators, that deal with locally-owned suppliers selection (e.g. CORE EC6). 

I consider the proposed disclosures related to supply chain not appropriate. Organizations with a huge number of suppliers might 

encounter problems in mapping their supply chain and in gathering too detailed data on it. Costs might be high to get information 

that might be not so material. 

Financial 

Markets & 

Information 

Users 

Europe 

Reporter 


I think the indicators are effective, but not always necessarily feasible. Business Northern 

America 

i. Should the Guidelines refer to the definition of Supply Chain in DI 12 in Disclosure DI 11? You might be at D1 11 and wonder what Mediating Europe 

is required here or what is meant by supply chain. Could DI 11 and DI 12 be switched in order? 

Institution 

ii. For Disclosure D1 12 – GRI is asking companies to provide some disclosure on the risks and impacts associated with their supply 

chain. In particular, GRI is asking for companies to comment on where their suppliers might be operating in weak governance zones 

and Export Processing Zones. Are these the only risks GRI wishes companies to take into account at this stage? What about other 

human rights risks (i.e., those identified in John Ruggie HR Framework)? 

iii. For Disclosure D1 22 – GRI has added Supplier Satisfaction Surveys, what about adding Customer Satisfaction Surveys as well? 

Customers are an important stakeholder, and often a driver for sustainability initiatives within companies. 

iv. For Disclosure DI 24 – GRI is asking companies to explain their process for defining report content, including how the report 

content was “Validated to ensure all relevant GRI reporting principles have been applied” (4th item in list). Does GRI offer guidance 

somewhere on what an appropriate validation mechanism or approach might be? 

v. Under Guidance for Disclosure on Goals, may want to add some additional guidance on goal and target setting. Using GRI 

indicators is one input, but GRI could introduce the pro’s and con’s of setting absolute vs. intensity-based vs. context-based metrics. 

vi. Aspect - Procurement Practices – Not clear on rationale behind why G4 1 and G4 2 are core indicators, or indicators of the overall 

sustainability of an organization. One asks about long-term relationships with suppliers (implying that loyalty, strong relationships 

with suppliers, and stability is valuable) and the other seems to imply that identifying and purchasing from new suppliers is also 

valuable. Seem somewhat contradictory. 

vii. For G4 4 – wondering if GRI could provide some references / resources for reporting organizations to refer to. i.e., lists of 

environmental/ social / economic standards are credible? And what are some of these economic standards GRI is referring to? 

Reporter 

Consultant 



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Information required about supply chain may be very sensitive and not disclosed. For example, total monetary value broken down 

by locations is something that will not be disclosed. 

Disclosures 12 and 18 are covering the same, since the value chain comprises the supply chain. The same happens with DI 17 a DI 19. 

Item G4 4 (line 698-700) is difficult to answer as definition of “verified or certified as being in accordance with credible, widelyrecognized 

economic, environmental and social standards” is not standardized and unclear. 

Mediating 

Institution 

Europe 

Reporter 

Consultant 

Report Reader 


Le concept n'est pas adapté pour les organisations publiques qui connaissent de façon implicite leur chaîne d'approvisionnement et 

qui sont régulièrement contraints par les lois dans le nombre et le type de fournisseur avec lesquels ils font affaire. 

Line 582 on p. 45 (Supplier selection): This indicator references economic, environmental and social criteria that may be used to 

select suppliers. Governance seems to be missing. There may be occasions when an organization also takes supplier governance 

into account upon evaluating suppliers for selection. 

Many of the disclosures proposed will be practically impossible for many industries to report at a global level. See comments in the 




















Mediating 

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America 

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Financial Northern Report Reader 

Markets & America 

Information 

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America 


Reporter 

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America 




America 



Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 


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Many of the disclosures proposed will be practically impossible for many industries to report at a global level. The repetitive nature 

of the indicators linked to supply chain increase complexity and the potential for confusion in reporting. 

Many of the disclosures proposed will be, from a practicality point of view, impossible for many industries to report at a global level. 

See comments in the Document Review section for some examples. 

Maybe there are too many core disclosures related to the supply chain 

No, because of the relatively long and too detailed input regarding the supply chain issues. It must be considered that in G3 

guidelines these issues are really very few and now it seems to be an unexpectedly high step forward. Although that the part of the 

Supply Chain is analytical and complete, it seems suddenly to be too demanding and therefore difficult to be answered/covered. 




Note that disclosure of supplier spends/monetary value is often proprietary, especially when you ask to break down those spends by 

type of product or service. Also would recommend not adding "Core G4 1 and Core G4 2- these do not seem relevant to 

understanding strategy or performance in a meaningful way. 

On DI 12, line 109, there is emphasis in the identification of suppliers in “weak governance” zones. In our view, suppliers expose the 

organization to other risks such as water scarcity. So maybe at this stage the location of suppliers can be linked to any ESG risk. 

On DI 12, line 109, there is emphasis in the identification of suppliers in “weak governance” zones. In our view, suppliers expose the 

organization to other risks such as water scarcity. So maybe at this stage the location of suppliers can be linked to any ESG risk. 

On DI 12, line 109, there is emphasis in the identification of suppliers in “weak governance” zones. In our view, suppliers 

expose the organization to other risks such as water scarcity. So maybe at this stage the location of suppliers can be linked to 

any ESG risk. 


America 



Business 

Mediating 

Institution 

Mediating 

Institution 

Mediating 

Institution 

Business 

Financial 

Markets & 

Information 

Users 

Financial 

Markets & 

Information 

Users 

Financial 

Markets & 

Information 

Users 

Northern 

America 

Europe 

Europe 

Europe 

Northern 

America 

Over prescriptive, burdensome and don't account for level of risk. Business Northern 

America 

Europe 

Asia 

Europe 

Reporter 

Reporter 

DRINKING 

WATER 

SUPLYER AND 

WASTE WATER 

TREATMENTS 

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Consultant 

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Data provider 

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Partially 

- For large, complex organizations with more than one business focus, with several supply chains and a global presence the “Supply 

Chain Disclosure” poses severe challenges. 


- The disclosure is too complex and requires significant and unduly investment in time and resource for implementation of data 

gathering and monitoring 


Please see answer to 2. Business Northern Consultant 

America 

Please see Q2 


Consultant 

Institution 

Assurance 

Provider 

pls see comments below 

refer to term and definition 

Requirement for data-intensive approach does not take into consideration the nature and complexity of supply chains 

Most companies, even the larger companies - who have the necessary resources and have been publishing a GRI based report for 

some time - will find the supply chain linked disclosure elements extensive, expensive to assess and premature to even start looking 

at some of the indicators. Many of the new indicators on supply chain are marked CORE. 

The complications in adopting this kind of directive data-intensive approach are side-stepped e.g. the fundamental nature of deep 

supply chains and complexity in assessing them. Some of these are 

a) Multi layered supply chain with complex dependencies of local economy and livelihoods 

b) Influence is sometimes dependent on the direct revenue contribution of business relationship with the supplier 

c) Language and diversity barriers - communicating ESG is challenging with many of the local suppliers (reporting organizations can 

but only do this progressively). 

Moreover, companies should adopt a non-enforcing enabler approach in their supply chain engagement – especially in economies 



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Requirement for data-intensive approach does not take into consideration the nature and complexity of supply chains :- 













GRI G4 framework, like its predecessor G3.1, unfortunately seems to advance this unilateral, data intensive, and compliance focused 

approach to supply chain engagement. 


Mediating 

Institution 

Asia 

Consultant 

Certified 

Training 

Partner & 

Consultant on 


Reporting 








b) Influence is sometimes dependent on the direct revenue contribution of business relationship with the supplier c) Language and 

diversity barriers - communicating ESG is challenging with many of the local suppliers (reporting organizations can but only do this 

progressively). 


and countries where a uni-dimensional approach on ESG aspects can sometimes go against the basic human 



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rights (livelihood and humanitarian) principles in the absence of alternatives coming from fundamental and systemic changes in the 

local economy. The GRI G4 framework, like its predecessor G3.1, unfortunately seems to advance this unilateral, data intensive, and 

compliance focused approach to supply chain engagement. 

Requirement for data-intensive approach does not take into consideration the nature and complexity of supply chains. Business Asia Reporter 

Requirement for data-intensive approach does not take into consideration the nature and complexity of supply chains: - Most 

companies, even the larger companies - who have the necessary resources and have been publishing a GRI based report for some 

time - will find the supply chain linked disclosure elements extensive, expensive to assess and premature to even start looking at 

some of the indicators. Many of the new indicators on supply chain are marked CORE. 







but only do this progressively) 






Same as question 2. Business Latin America Reporter 

Same comment as above -- In general, we do not see much value in adopting all of the G4 expectations in our supply chain 


processes as the definition of “supplier” includes certain suppliers (e.g. home workers, primary producers, wholesalers, 

subcontractors) that we do not deal with directly . Therefore, we would have no information on these suppliers in order to respond 

to indicators such as HR2 - screen for human rights abuses etc. In general it will not be practical nor will be of much benefit to the 

organisation to attempt to report on all the supply chain related reporting requirements outlined in G4. 

Screening of social impacts is burdensome and does not add sufficient value to include it. 

Mediating 

Institution 

Oceania 

Reporter 

Consultant 

Report Reader 

Report Reader 

see #1 

Civil Society Latin America 

Organization 

see above Business Europe Reporter 



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See above 

Mediating 

Institution 

Europe 

Consultant 

Assurance 

Provider 

Reporter 

See above. Business Northern 

America 

See above. Business Europe Reporter 

See above. It is not clear what the purpose is of the detailed data disclosures, and why similar indicators are repeated for 


environment, labour practices, human rights etc. As noted later, the separation into G4.7, G4.10 and HR 11 indicators – related to 

grievance mechanisms - are particularly problematic since the distinction between ‘human rights related grievances’ and ‘nonhuman 

rights related grievances’ is often extremely difficult to apply in practice. 

Apart from the indicators, the added value and purpose of the extensive broken down information in standard disclosure D 12 

(page 29) is unclear. Added to this, the long un-referenced list of DMA supply chain disclosure items on pg 66-67 is also repetitive 

and broken down too much This information could be easily aggregated as it is unlikely that a reporting organization will have the 

resources or capacity to report on each item separately. 

As mentioned in response to 2 above, there is also no clear merit to having three separate indicators for screening, assessment and 

grievance mechanisms and no explanation in the proposed guidance related to this decision. 

See answer to point 2. Business Europe Reporter 

See answer to question 3 above. It is not clear what the purpose is of the detailed data disclosures, and why similar indicators are Business Northern Reporter 

repeated for environment, labor practices, human rights etc. 

America 

G4.7, G4.10 and HR 11 indicators – related to grievance mechanisms - are particularly problematic since the distinction between 

‘human rights related grievances’ and ‘non-human rights related grievances’ is often extremely difficult to apply in practice. There is 

also no clear merit to having three separate indicators for screening, assessment and grievance mechanisms and no explanation in 

the proposed guidance related to this decision. 



Consultant 

Institution 

Report Reader 

See my response above. 

Civil Society Northern Consultant 

Organization America Report Reader 

R&D in 

reporting 

See question 2. Business Europe Reporter 



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See response to question 2 above. 

In addition, it appears there are redundancies in the information requested. For example, is a separate breakdown of data between 

new and existing suppliers necessary? It shouldn’t be – they are both part of your supply chain and same rules should apply to both. 

Subsequently, results on both should be combined when reported. 

Business 

Northern 

America 

Significant expansion of the burden of reporting without clear additional value Business Northern 

America 

Some of the new required disclosures might compromise supplier confidentiality or provide a competitive advantage to the 

reporting company or a supplier’s competitors if they plan to bid for a contract in the future. 


America 

Supply chain disclosures in the DMA should instead be individual indicators or be included with DI 12. Business Northern 

America 

Supply chain-specific Indicators should push organizations to disclose specific information on “Forms of Social and Economic 

Civil Society Europe 

Inclusion’ as a way of extending organizations commitment to responsible business practices to their value chains, including 

Organization 

information linked to disability, such as: 

› Percentage of social businesses owned or staffed by people with disabilities and monetary value of the goods and services 

provided 

› Specific invitations to tenders, evaluation criteria, contract terms and conditions, that consider the evaluation of number of 

employees people that are people with disabilities 

› Suppliers compliance of legislation that sets a quota for the employment of people with disabilities, if applicable. 

By disclosing that information organizations are accountable of their social and economic impact via supply chain in terms of: 

Reporter 

Reporter 

GRI 

Consortium 

Member 

Reporter 

Reporter 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

› Its contribution to the social inclusion of vulnerable groups (e.g. through the promotion of employment of people with disabilities 

in the value chain, or the application of specific criteria regarding accessibility performance of goods and services provided by the 

suppliers). 

› Shifts on responsible social purchasing investments, which could be also of great interest in public procurement that values social 

businesses engagement or responsible products and services (e.g. accessibility, among others) as benchmarking factors. 

That will have to be determined by the stakeholders demands and the relevance of these to the reporting organisation. 

The complete supply chain should be important, but not a requirement to report by GRI standards. There are material suppliers that 

cannot be approached in the medium term, and small organizations do not have power to do so. 

the content is appropriate, but see document for comments on description. 

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The disclosure of supply chains should not only comprise the number of suppliers and their location by country. Instead it should 

become mandatory to disclose a complete list of all suppliers within the supply chain and not only those located in Special Economic 

Zones. Each companie should provide a complete supplier list comprising in a first step the First Tier suppliers, but in a long run (a 

period of time should be defined, in which the company has to collect the data) also the Second and Third Tier suppliers should be 

stated, including supplier name, nature of the business, contact details, production site(s) and so on. 

The disclosure requirements have to be contextual and for supply chain the indicators stipulated are not possible. If there is genuine 

requirement of CEO/Board level sign off, I think understanding of data challenges need to be understood better in the Indian 

context. These are simply not doable 

The disclosures are comprehensive but they will be a challenge for many companies to report in full due to the nature of their large 

and complex supply chains. 

The effectiveness of the indicators depends upon what types of activities are being handled by the supply chain and varies for every 

industry. For example, in a manufacturing setting, the disclosures are relevant as a "dirty" portion of the business may have been 

outsourced to make the company "look better." In a non-manufacturing scenario, this becomes much less appropriate. Purchases by 

non-manufacturers, for example, of office supplies, help to drive the market for sustainable goods and services, but do not directly 

contribute to the company's "product" in the same way it would for a manufacturer. Flexibility is key. 

The focus on local suppliers seems to unduly make it seem like that should be the only focus. In some countries, the focus could be 

on other groups of suppliers, for example, disadvantage business enterprises including minority and women owned businesses. Only 

asking about local suppliers is too narrow to capture relevant supply chain impacts. 

The guidance seems to ask for organisations to report on everything that can be measured and reported rather than on what 

matters. It would be much better to have organisations reporting on a few initiatives, or potentially how they are working with the 

supply chain to improve upon sustainability issues, and measuring the impact it has.. It resembles more a checklist, which would 

benefit from a compelling narrative. 

The increase in disclosure requirements with respect to suppliers, including a supply chain, may not be useful to readers of the 

report and create an undue amount of work for the company to compile this information. These changes need to be reassessed in 

terms of relevance and materiality. 

The location of suppliers should be linked to ESG risk in general. 

The proposed disclosure is too detailed. Companies should only report on direct suppliers at max. Indirect suppliers should improve 

via influence on direct suppliers. 

Competitiveness reasons might obstruct transparent reporting on suppliers. 

It should be determined which country is ´high risk´. 

Civil Society 

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It is not a good idea to look into the salary scales of all suppliers. 

An organization cannot be expected to report on all suppliers, but only on core/ material/ relevant. 

The proposed disclosures could be enhanced if preparers were encouraged to explain their respective contribution to value creation 

and/or preservation. 

The proposed updates to Disclosure DI 1 and DI 11 are not appropriate for inclusion at this time. 

Mediating 

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First, Disclosure DI 1 states "This includes impacts... that can be linked to ...as a result of relationships with others (eg. suppliers, ...)". 

This statement is too broad reaching in terms of tracking suppliers. Realistically for the average-staffed organization, the 

responsibility is with the direct products and/or services that are procured from the supplier. Therefore, DI 1 should specify if the 

impacts are "direct" and/or "indirect" in terms of the relationship with others. In addition, if retained, it should state how far 

upstream or downstream the impacts should be evaluated. 

Second, there are also concerns with Disclosure DI 11 in regards to sharing specific information around supplier names, locations, 

selection, termination, types of supply, and monetary value as some of the information is confidential from a business perspective 

as well as trade secrets. 




The required disclosure goes to far. E.g. why are changes in relationship material? 

Mediating 

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Information can be relevant for competition and therefore not disclosed. 

The suggested disclosures are too comprehensive and not precise enough. Requested information must be clear for reporting 

organizations, exact requirements need to be determined in order to be clear which reporting content needs to be covered in order 

to check accordance with GRI guidelines. Further, the reporting organizations should be required to disclose which supplier tier(s) 

are reported (e.g. in DI 12 Total number of suppliers but also with view the application of the procurement practices). 

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The supplier disclosures have gone too far and have become a bit ridiculous. To report all of these requirements would necessitate a 

report all on its own. It would also require new resources and systems to be implemented. Companies with large supplier bases that 

consist of large corporate to small enterprises would find it very difficult report to this level. I suggest that this be relooked and 

simplified to the most critical and reasonable measure. 

The topic is appropriate but what you're asking for is way too much information. 

There must be the possibility to focus on core suppliers. 


Mediating Northern Assurance 

Institution America Provider 


Competitiveness and legal reasons will obstruct transparent reporting on suppliers in the level of detail proposed 

There should be more recognition that in this area a risk based approach is needed. Actions should be prioritised on mitigation in Business Europe Reporter 

areas of highest risk. GRI should consider merging social and environmental indicators into fewer indicators. The number of 

indicators suggested is not simplifying matters. 

They need to be extended upstream to the clients Business Europe Reporter 

Report Reader 

This depends on the definition of supplier and to what extent an organization (especially small and medium-sized entities) has to Mediating Europe 

Consultant 

comprehend its supply chain (to which degree/ level of supplier). If an organization (especially a small and medium-sized entity) has Institution 

Report Reader 

to report on all suppliers we would not call it appropriate. 

for academic 

purposes 

this will be an enormous task - getting the information/data from organisations you have no control over. It is impossible to verify 

the data 

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GRI trainer 

Too detailed. Many info is confidential Business Europe Reporter 

too much granularity introduced. Business Northern Reporter 

America 

Too onerous and over-complicated. 

Mediating 

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We believe that occupational safety and health should be covered far more effectively within the proposed disclosures related to 

supply chain issues. 


Our members 

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We find that there is too much focus and information required on Supply Chain. Business Europe Reporter 

While appropriate, they are not complete. Some areas are covered in detail, such as environmental, while other areas such as 

occupational safety and health receive very little if any focus. Failing to properly evaluate worker safety and health could lead to dire 

consequences (like the factory fires in Pakistan earlier in September killing 314 workers, or the garment factory fire in Russia that 

killed 14). 

Civil Society 

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Northern 

America 

Report Reader 

While appropriate, they are not complete. Some areas are covered in detail, such as environmental, while other areas such as 

occupational safety and health receive very little if any focus. Failing to properly evaluate worker safety and health could lead to dire 

consequences (like the factory fires in Pakistan earlier in September killing 314 workers, or the garment factory fire in Russia that 

killed 14). 

While the G4 draft generally encourages reporters to comment on the economic impacts of our entire supply chain, it should also 

include specific disclosures pointing to the economic benefits that Southwest Airlines provides to the communities in which we 

operate. Economic disclosures should include not just relationships with suppliers but also the benefits directly provided by 

Southwest Airlines. 

Civil Society 

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Additionally, it is not clear in G4 how far upstream and downstream we should report. In particular areas, such as energy use from 

different sources, we may need to provide more general management and policy information rather than detailed supply chain 

information. G4 should account for such flexibility in its reporting mechanisms. 

While the G4 draft generally encourages reporters to comment on the economic impacts of the entire supply chain, it should also 

include specific disclosures pointing to the economic benefits the organization itself provides to the communities in which it 

operates. Economic disclosures should include not just relationships with suppliers but also the benefits directly provided by GRI 

reporters. 

Mediating 

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Northern 

America 

Report Reader 

Additionally, it is not clear in G4 how far upstream and downstream an organization should report. In particular areas, such as 

energy use from different sources, organizations may need to provide more general management and policy information rather than 

detailed supply chain information. G4 should account for such flexibility in its reporting mechanisms. 

Yes, but for a national corporation –not multinational- indicators such as the spending on locally-owned suppliers may not be so 

relevant. In this case, what will be the definition of local? 

Yes, but must emphasize and repeat reference to “Part 4: Technical Protocol for Defining Report Content and Boundaries” which 

guides on how the materiality principles should be applied in order to not misinterpret the extent of the supply chain that is 

necessary for reporters to address. Please refer to comments given under question 2 of this section. 





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- As mentioned above companies do not have the required data. 

- Suggestion: A general set of indicators for all classes of business. 

- The mapping of the whole supply chain forms a contrast to the idea of materiality. 

- What is the purpose of mapping the whole supply chain? 

- The distinction of supply chain and value chain leads to overlapping. 

- The definition of “other business partner”, relating to the supply chain, is missing. 

- What are the arguments against the partial mapping of the supply chain? 

- there is a link with remuneration and benefits but nothing related to quality of life, health and safety that in my perspective are as 

important to demonstrate a supply chain sustainability or best practice 

- the supply chain indicators focus on selection and evaluation, but there is nothing to measure how much companies are investing 

to develop its suppliers and the whole supply chain for better practices 

• As mentioned above companies do not have the required data. 

• Suggestion: A general set of indicators for all classes of business. 

• The mapping of the whole supply chain forms a contrast to the idea of materiality. 

• What is the purpose of mapping the whole supply chain? 

• The distinction of supply chain and value chain leads to overlapping. 

• The definition of “other business partner”, relating to the supply chain, is missing. 




• What are the arguments against the partial mapping of the supply chain? 

• As mentioned above companies do not have the required data. 


• Suggestion: A general set of indicators for all classes of business. 

• The mapping of the whole supply chain forms a contrast to the idea of materiality. 

• What is the purpose of mapping the whole supply chain? 

• The distinction of supply chain and value chain leads to overlapping. 

• The definition of “other business partner”, relating to the supply chain, is missing. 



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• What are the arguments against the partial mapping of the supply chain? 

As per above 

As per my previous comment. The data surrounding supply chains involves a LOT of reliance on other entities to provide data ad 

could possibly result in double reporting and errors. 

Comment 1: Requirement for data-intensive approach does not take into consideration the nature and complexity of supply chains 

















Mediating 

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Definition of 'critical supplier' to facilitate classification in different corporate segments Business Latin America Reporter 

Definition of 'critical supplier' to facilitate classification in different corporate segments. 


Institution 


Mediating Latin America Reporter 

Institution 

Definition of 'critical supplier' to facilitate classification in different corporate segments. Business Latin America Reporter 




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For large organisations, it will be very difficult and time consuming. More over may not be relevant also. Business Asia Reporter 

For product and service design; identify changes, and describe their outcomes and progress: 

This description is vague. There should be an explanation of how companies could work with suppliers to influence the way their 

products are designed and manufactured. For example, collaborating on a project that connects manufacturers with customers’ 

feedback, via the reporting company. 

For reporting policies and practices used to select locally-owned suppliers, either organization-wide or for specific locations: 

Mediating 

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Northern 

America 

Reporter 

Consultant 

‘Locally-owned’ is very specific. A locally-produced good or service is (usually) the superior option environmentally, however the 

business may not necessarily have a local owner. 

For the same principal objective of disclosure I think, I do not have certain that for supplay chain need to observed the same 

discussions elaborated for IFAC and principally https://www.ifac.org/publications-resources/competent-and-versatile-howprofessional-accountants-business-drive-sustainab 

In addition to comments provided to earlier question: 

Mediating 

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Comment1: Reporting grievances to the detail prescribed in the G4 Guidelines, as per indicators G4 7 and G4 10, can compromise on 

privacy and protection of the person who raised the grievance: 

Disclosing details of grievances filed, by nature and location and specific party, may take away the confidentiality that is the essence 

of whistleblower policies. Grievance reporters require protection and therefore, public disclosure of ‘who’ and ‘where’, by stating 

the type of stakeholder and consequent diversity related disclosures of the person does not seem appropriate. 

Comment 2: 



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Another factor is that companies tend to have non-disclosure agreements with their suppliers, which is proprietary and 

confidential information that cannot be publicly disclosed. 

Just one apprehension, as far as reporting and disclosing this goes, it will be feasible. But how reliable the supply chain data is going 

to be and whether it would make sense for the reporting organisation to take responsibility for data coming from their supply chain. 

This will especially be relevant for organisations which are into assembly rather than manufacturing for example automobile sector 

in India. 



Most of the disclosures are related to some negative issue. I wish there were several 'positive' disclosures. 

No, asking for too much information that is not clearly useful. 







No, way tooo much detail is asked, such DI12: „Description of Supply Chain may include, but is not limited to: 

Civil Society 

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Mediating 

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condition of 

membership 

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researcher and 

educator 

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Provider 

This information will make (in-accordance) sustainability way too long. Moreover, which report user group would be interested in 

this information and really "use"? 

not complete 

not complete 

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research 



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not complete Business Latin America Reporter 

not complete 


Institution 



Please see comment in response to question four. Business Europe Reporter 
















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Requirement for data-intensive approach does not take into consideration the nature and complexity of supply chains :- Most 



some of the indicators. Many of the new indicators on supply chain are marked CORE. The complications in adopting this kind of 

directive data-intensive approach are side-stepped e.g. the fundamental nature of deep supply chains and complexity in assessing 

them. Some of these are a) Multi layered supply chain with complex dependencies of local economy and livelihoods b) Influence is 

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sometimes dependent on the direct revenue contribution of business relationship with the supplier 






GRI G4 framework, like its predecessor G3.1, unfortunately seems to advance this unilateral, data 

intensive, and compliance focused approach to supply chain engagement. 






























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Requirement for data-intensive approach does not take into consideration the nature and complexity of supply chains :- Business Asia Report Reader 



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Moreover, companies should adopt a non-enforcing enabler approach in their supply chain engagement – especially in 

economies and countries where a uni-dimensional approach on ESG aspects can sometimes go against the basic human rights 

(livelihood and humanitarian) principles in the absence of alternatives coming from fundamental and systemic changes in the local 

economy. The GRI G4 framework, like its predecessor G3.1, unfortunately seems to advance this unilateral, data intensive, and 


















Requirement for data-intensive approach does not take into consideration the nature and complexity of supply chains :- Business Asia Assurance 

Provider 

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Requirement for data-intensive approach does not take into consideration the nature and complexity of supply chains :- Business Asia Report Reader 



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Same as above Business Asia Report Reader 

Academic 

See above. 


Consultant 

Institution 

See comment above. 


Report Reader 

Markets & 

Information 

Users 

See general comment at the end of this document. 

Seems complete and appropriate, however, there could be some practicability issue. such as with Core G4-6 and core G4-9. 

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proivde range 

of consulting 

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Researcher and 

Journalist 

Sure they are complete, again I fear the bar has been raised too much and that could make them unappropiate. Business Europe Reporter 

The disclosures are over prescriptive. They should be replaced by simple, principle based disclosures. Many of them should be part Mediating Asia 

Report Reader 

of the ‘comply or explain’ basis. 

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preparer. 

Current 

Academic 

The disclosures for supply chain are unneccesarily burdensome. Why would large companies need to do a full accounting of their Business Northern Reporter 

supply chain, broken down to such a micro level? 

America 

The importance of suppliers and impact various indistruies can have on their suppliers varies greatly. Too much emphasis on Business Northern Reporter 

suppliers in the financil industry may not make sense. 

America 

The lack of a definition of "significant suppliers" is a problem. Business Latin America Reporter 

Report Reader 

The lack of a definition of "significant suppliers" is a problem. Business Latin America Reporter 

The lack of a definition of "significant suppliers" is a problem. 

The nature and complexity of supply chains need consideration before adopting such a data-intensive approach. Most companies, 

even the larger companies who have the necessary resources and have been publishing a GRI based report for some time, will find 

the supply chain linked disclosure elements extensive, expensive to assess and some indicators even premature to even start 

looking at them. Many of the new indicators on supply chain are marked core and essential. The complications in adopting this kind 

of directive data-intensive approach are phenomenal given the fundamental nature of deep supply chains and complexity in 

assessing them such as: 

Financial 

Markets & 

Information 

Users 

Latin America Reporter 











The requirements for supply chains are much too detailed. Many companies are starting to screen their supply chain an dare willing 

to describe the process but may be less open to report on all the indicators. 

The same as explained in paragraph No1, supply chain is the complete chain so the indicators, should explain the impact of the 

complete process (as for example, life cycle assesment) 


Report Reader 


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They are certainly "complete", but I don't think it appropriate to require that level of completeness. Business Northern 

America 

too detailed and too long 


Institution 

Why not name all the suppliers by country, region, type, size of business etc.? It'd be truly transparent 


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Q4) Do you consider the proposed guidance provided to support disclosure on supply chain related issues appropriate 

and/or complete? 

Yes 




52 

% of 

submissions 

answering 


further 

comments 

% of 

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offering 

comments 

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• ERM suggests that GRI revise the “Screening and Assessment/Remediation” aspect in all the indicator categories. While this is an 

excellent way to capture supply chain impacts across all indicator categories, there is too much overlap. Many companies manage 

supply chain as its own issue. ERM recommends GRI capture this aspect in another way. 

• The definition of what is considered “material” differs a lot among stakeholders. The guidance should clarify in a concise manner 

how G4 defines “material” issues. Especially for large companies it would be very difficult to report “in accordance” with G4 since a 

very large number of supply chain-related issues will be material. 

• GRI could consider to introduce a differentiation between „significant“, „material“ and „top-material“ suppliers – otherwise 

reporters will make their own choice at the expense of comparability. 

• A clarification of key terminology in this context, especially “local suppliers”, would be helpful. 

• The guidance should also clarify in a concise manner how to deal with supplier targets and objectives (e.g. a Supplier Code of 

Conduct and Terms and Conditions). 

•Deutsche Bank supports Econsense’s assessment that for large companies it would be very difficult to report “in accordance” with 

G4 since a large number of supply chain-related issues will be material. 

Additional guidance for some Indicators could be helpful. For example, for CORE G4 6 (Percentage of existing suppliers and other 

business partners identified as having actual and potential adverse impacts on the environment assessed on environmental 

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performance, and actions taken) some guidance or list of values for the nature of the issue would be valuable. 

The magnitude of required disclosures is unclear. More guidance could be provided regarding how to define which suppliers to 

include in the report, and how much specificity to disclose on these suppliers. 

Again, too complicated. 

Again, workplace auditors role reported on. We realize this could be seen as subsumed under management practices, but data on 

auditors and outcomes is important. We continue to believe women's health and worker health, outside of occupational health and 

safety, to be under-represented, even though you cite CEDAW in you list of conventions. Particularly where supply chains employ 

50% plus women there are huge issues related to CEDAW that is skated over. Also, you suggest a human rights assessment, but if a 

company is serious about gender they will consider a gender assessment, which is a different tool for identifying disparate impacts 

on men and women. This is not just a supply chain issue. 

Mediating 

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As guidance this is complete but the actual requirements for disclosure are unrealistic as per the previous answers. Business Africa Reporter 

Covered in earlier questions Business Asia Reporter 

DI 12 #2 b (line 106) – Further guidance could be provided on the nomenclature to describe different types of suppliers. 

Mediating 

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Displayed all over the document. Difficult to understand where to find it and the links between the different topics Business Europe Reporter 

Expectation for entire supply chain to be covered is an unreasonable requirement, similar to issues raised in the value chain 

approach of Content and Boundary 

The extent to which a company / organization intends to report on supply chain should be left to the discretion of the organization. 

Instead of reporting about the entire supply chain, it will help companies to focus on significant suppliers for driving sustainability in 

respective supplier’s organization. 


approach of Content and Boundary: - The extent to which a company / organization intend to report on supply chain should be left 

to the discretion of the organization. Instead of reporting about the entire supply chain, it will help companies to focus on significant 

suppliers for driving sustainability in respective supplier’s organization 


approach of Content and Boundary:- 





Report Reader 


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Reporting 

Expectation for entire supply chain to be covered is an unreasonable requirement. Business Asia Reporter 



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Given the proposed expansion of reporting boundaries and increased detail of supply chain indicators and disclosures we question 

whether reporters can fashion responses to the disclosure that are meaningful and material. 

Guidance on assessing supplier social impacts needs further work 

Guidance seems to cover relevant aspects, reference to further (external) information regarding Responsible Supply Chain 

Management and Supply Chain Reporting may be necessary to clarify this complex topic. It should be made clear that responsible 

pro-curement practices and supplier monitoring activities may be applicable to certain sup-plier tiers in certain supply chains only 

due to limited influence or transparency in the supply chain. 

Hess concurs with the following response to this question submitted by IPIECA: 

Business 

Mediating 

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Reporter 

It is always a challenge to define the supply chain beyond the primary suppliers. There is little discussion or guidance on this. In 

addition, companies may have thousands of small suppliers, some providing only minor or even trivial goods or services, and some 

being large, multinational established reporters themselves. There is no guidance to help prioritisation for reporting or determining 

what impacts are of importance to stakeholders (to support the materiality process). This is particularly for core indicators, such as 

HR5, HR6 and HR7, where G4 removes the term “significant” suppliers. 

Some guidance on legal and commercial considerations when reporting grievances from suppliers would also be highly beneficial. 

Important is to separate suppliers that work inside the production process of an organization. This is a very important type of 

supplier, because its impacts are the impacts of the organization itself. 

The term LOCAL must be defined by GRI guidance. Some companies consider a state as local! 

What shoud be done if supply chain is not a material issue? In this case report should not enter all details covered by indicators and 

other disclosure requirements. Has this been considered? 

In G3 there are several inconsistencies in the guidance of performance indicators. The guidance should be detailed and compiled 

with care to provide sufficient support and clear definitions for the reporters. 

It can be useful, but always when considered as guidance as opposed to requirement. 

It doesn't provide appropriate guidance for occupational health and safety. "Workplace conditions," for example, is very poorly 

defined, but is possibly the most direct reference to worker safety and health. 

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It doesn't provide appropriate guidance for occupational health and safety. "Workplace conditions," for example, is very 

poorly defined, but is possibly the most direct reference to worker safety and health. 

It is always a challenge to define the supply chain beyond the primary suppliers. There is little discussion or guidance on this. In 

addition, companies may have thousands of small suppliers, some providing only minor or even trivial goods or services, and some 

being large, multinational established reporters themselves. There is no guidance to help prioritisation for reporting or determining 

what impacts are of importance to stakeholders (to support the materiality process). This is particularly for core indicators, such as 

HR5, HR6 and HR7, where G4 removes the term “significant” suppliers. 





It's way to broad. We would expect the GRI to address how information should be aggregated. Business Northern Reporter 

America 

Many of the disclosures proposed will be practically impossible for many industries to report at a global level. See comments in the Business Europe Reporter 


Many reporting entities such as airlines add an incredible level of economic value to the communities, states, and nations in which Mediating Northern Report Reader 

they operate. While the G4 draft generally encourages reporters to comment on the economic impacts, it should include guidance Institution America 

on specific disclosures pointing to the economic benefits the organization itself provides to the communities in which it operates. 

Economic disclosures should include not just relationships with suppliers but also the benefits directly provided by GRI reporters, 

and the guidance should reflect this point. 

Additionally, guidance should include definitions of terms that could prove confusing when organizations prepare reports. These 

terms include 'indirect energy use' and 'country of significant operations.' 

Also, the provided guidance isn't clear on Core Disclosures G4 6, HR2, and other similar supplier-related disclosures, regarding 

reporting the suppliers and other business partners having adverse sustainability impacts. It isn't apparent who would determine 

that such suppliers have adverse impacts other than the reporter itself, raising questions on subjectivity and overall reporting 

consistency. 

Finally, on a specific point, Disclosure Core G4 2 appears to include a false assumption in stating that a high turnover of suppliers 

quantifies the stability of an organization's supplier base, thereby highlighting an ineffective relationship management between the 

organization and its suppliers. In complex businesses, a multitude of reasons may cause a high turnover of supplies, including 

market uncertainty and a recession disproportionately impacting particular sectors. The disclosure should be removed. 

More guidance is needed on the concept of value chain and where to draw the box around what is included and excluded in an 

organization's value chain. This comment applies both to supply chain disclosures and the changes made in establishing the 

boundary of the report. 

Much of the guidance proposed will be practically impossible for many industries to follow, as it is too complex and too 

cumbersome at a staff level. See comments in the Document Review section for some examples. 

Much of the guidance proposed will be practically impossible for many industries to report at a global level. See comments in the 

Document Review section for some examples 

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America 

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America 



Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 


America 


America 








Much of the guidance proposed will be practically impossible for many industries to report at a global level. See comments in the Business Africa Reporter 


No comment. Business Europe Reporter 

Not enough guidance on how to prioritise risk; e.g. geography vs issues. Business Europe Reporter 

Over prescriptive, burdensome and don't account for level of risk. Business Northern Reporter 

America 

p. 111 EC6 –line 1243 – guidance is unclear. Business Northern Reporter 

America 

Partly 


• The definition of what is considered “material” differs a lot among stakeholders. The guidance should clarify in a concise manner 




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• Targets and objectives are not included in normal contracts. Basis might be a Supplier Code of Conduct and in Terms and 

conditions. Targets and objectives are important means with regard to Supplier management/supplier development: they may be 

part of a corrective action plan after an assessment or audit. Another reason respectively necessity might be regulatory 

requirements, e.g. REACH. 

• Companies usually do not themselves certify suppliers according to int. certifications. We ask for int. certifications in our 

assessments. 

• Please specify product and service design. 

Partly 


• The definition of what is considered “material” differs a lot among stakeholders.The guidanceshouldclarify in a concise manner 

how G4 defines “material” issues.Especially for large MNEs it would bevery difficult to report “in accordance” withG4since a very 

large number of supply chain-related issues will be material. 






Partly. 


The definition of what is considered “material” differs a lot among stakeholders. The guidance should clarify in a concise manner 



GRI could consider to introduce a differentiation between „significant“, „material“ and „top-material“ suppliers – otherwise 


A clarification of key terminology in this context, especially “local suppliers”, would be helpful. 



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The guidance should also clarify in a concise manner how to deal with supplier targets and objectives (e.g. a Supplier Code of 


Partly. 


The definition of what is considered “material” differs a lot among stakeholders. The guidance should clarify in a concise manner 



GRI could consider to introduce a differentiation between „significant“, „material“ and „top-material“ suppliers – otherwise 


A clarification of key terminology in this context, especially “local suppliers”, would be helpful. 

The guidance should also clarify in a concise manner how to deal with supplier targets and objectives (e.g. a Supplier Code of 



Please see Q2 


Consultant 

Institution 

Assurance 

Provider 

pls see comments below 

Mediating 

Institution 

Oceania 

Reporter 

Consultant 

Assurance 

Provider 

Report Reader 


Se debe dar claridad entre cadena de valor y cadena de suministro, ya que no son lo mismo y se debería incluir dentro de las 

definiciones. 

see answer nr. three 

See comments above. 


Mediating 

Institution 

Mediating 

Institution 

Europe 

Northern 

America 

Consultant 

Report Reader 

for academic 

purposes 

Reporter 

Industry 

Association 



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See my responses above. 

Mediating 

Institution 

Civil Society 

Organization 

Europe 

Northern 

America 

Consultant 

Report Reader 

Consultant 

Report Reader 

R&D in 

reporting 

See question 1. Business Europe Reporter 

Separation between supply chain and value chain partially unclear. Supply chain only relates to the first half of value chain. Business Europe Reporter 

Some of the guidance terms are too vague. For example, it is not clear whether auditing of suppliers includes corrective-action 

auditing or informal review. For the certification question, is it appropriate for the certification to be self-certified, or does this need 

to be third-party certification? Terms such as “small” and “medium” need to be clarified. Are foreign and domestic suppliers held 

to the same standards? To what extent should screening be performed and what are the required attributes of screening? These 

are just a few of the areas in which the guidance should be clarified. Ultimately, EPRI agrees with the increased emphasis on supply 

chain and would welcome the opportunity to engage further on this subject with GRI. 

The guidance does not fully address how an organisation should group and prioritise suppliers. This could be problematic for larger 

organisations that have many suppliers who are often very small or provide a low volume of goods or services. Furthermore, the 

nature of the goods and services being supplied is not addressed which may hold some significance. The relative importance of 

suppliers will also need to be linked to the materiality process. 

The guidance is appropriate, however the location and structure of the information within the G4 is a little bit confusing. There are a 

lot of indications about new things to report, and in some cases the demand of information exceeds a lot the information 

companies have about their suppliers (for example in all the new inclusions in the labor DMA). 

It will be very helpful to concentrate all the indicators and information about supply chain in one aspect. In cases where this 

information may not be material, it is easy to not take into account the requirements if all the requirements are concentrated. 

The information is fragmented and many find it hard to follow. Supply Chain (SC) matters have expanded considerably. It would be 

helpful to have a concentrated section on Procurement and Value Chain. 

The is one of the biggest and most important changes it warrants a guidance document of its own. Certified Training Partner 

materials need careful consideration. Webinars for Supply Chain and Value Chain are also needed a long with case studies all i n due 

course 

We like the fact that supply chain is becoming better incorporated but have spoken to others who find G4 Supply Chain provisions 

over bearing and onerous, we feel that the amount of disclosure could be reduced whilst delivering good information to drive the 

company forward an keep stakeholders informed. There are also areas that are over detailed; see Technical comments which go 

through many of these. However overall the outcome is worth the effort if it provides the visibility that can drive sustainability into 

the suppy chain and develop greater responsibility amongst large reporting organisations. 

Supply chain satisfaction surveys may be a source if difficulty as suppliers are likely to be reluctant to comment adversely upon the 

hand that feeds them. 

Mediating 

Institution 

Northern 

America 

Report Reader 

Research 


Mediating 

Institution 

Mediating 

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Europe 

Europe 

Reporter 

Consultant 

Report Reader 

Reporter 

Consultant 

Report Reader 

GRI Certified 

Training 

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The proposed Disclosure DI 12 asks companies to “Describe the organization’s supply chain” (line 99). The guidance for this 

disclosure is extremely broad, including numerous criteria and sub-criteria that will make comprehensive reporting particularly 

onerous and unfeasible. For example, the requirement to report on “Total number of suppliers” using the new definition of 

suppliers provided in the G4 glossary may require companies to gather data on new classes of individuals and organizations than are 

currently tracked. The sub-criteria presented in lines 102-110 also pose a significant reporting burden for large companies with 

complex and variable supply chains, potentially requiring many pages listing numerous materials, products, services, and global 

locations. 

We suggest: that the GRI revisit the language of this disclosure to address how information could and should be aggregated in the 

case of large companies with large, complex supply chains. One particular issue to be addressed is how to define the term “Total 

number of suppliers”—i.e., whether this term reflects only direct (Tier 1) suppliers, or suppliers throughout the value chain. 

The proposed guidance calls for too many elements in too much detail. It might be more effective to suggest that a company 

should disclose material elements throughout its supply chain in the context of how it creates and preserves value. 

The provided guidance isn't clear on Core Disclosures G4 6, HR2, and other similar supplier-related disclosures, as they relate to 

reporting of suppliers and other business partners having adverse impacts on sustainability. It isn't apparent who would 

determine that such suppliers have adverse impacts other than the reporter itself, raising questions on subjectivity and overall 

reporting consistency. 

Mediating 

Institution 

Mediating 

Institution 

Business 

Northern 

America 

Asia 

Northern 

America 

Reporter 

Consultant 

Report Reader 

Reporter 

Consultant 

Assurance 

Provider 

Report Reader 

Reporter 

Disclosure Core G4 2 appears to include an assumption in stating that a high turnover of suppliers quantifies the stability of an 

organization's supplier base, thereby implying ineffective management of the relationship between the organization and its 

suppliers. In complex businesses, a multitude of reasons may cause a high turnover of supplies, such as market uncertainty and a 

recession disproportionately impacting particular sectors. Additionally, publicly held companies are in business to make a profit, and 

one of the tools that enable them to do so is to use competitive bidding to reduce the cost of their supplies. This disclosure should 

be removed. 

The references to Under-represented / Underrepresented groups, Vulnerable groups, Indicators of Diversity (suggested change to 

Diversity Groups), Marginalized Groups and “Economic Inclusion” (suggested change to Social and Economic Inclusion) and the 

definitions included at Glossary level should be unified along the GRI G4 guidelines. 

The disclosure of accessibility of workplace environment or acquired disabilities should be considered among the issues to report 

under Labor Practices and Decent Work category. 

Also, guidance that provides references of appropriate “institutional and legal frameworks” for a particular topic could be of great 

Civil Society 

Organization 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 



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help to implementation and disclosure of relevant issues linked to it. Regarding Disability, the United Nation Convention on the 

Rights of Persons with Disabilities (2006) should be included. 




Mediating 

Institution 

Europe 

Reporter 

Consultant 

Assurance 

Provider 

Report Reader 

Reporter 

the span of input requested is exhaustive, and it extends far beyond the scope of influence for the organization. how and why 

would we attempt to capture data on these elements? 


America 

There are significant new requirements in an area which many companies, either multinationals or SMEs, will struggle to report Business Northern Reporter 

accurately, especially without a phased transition period. 

America 

There is need for additional thinking about this section. Business Europe Reporter 

Accountancy 

body 

There is no guidance to help prioritization for reporting or determining what impacts are of importance to stakeholders (to support 

the materiality process). This is particularly for core indicators, such as HR5, HR6 and HR7, where G4 removes the term “significant” 

suppliers. 

Business 

Northern 

America 

Reporter 

Notably, the UN Guiding Principles on Business and Human Rights acknowledges the difficulty for large companies to assess all 

suppliers in their value chains. The commentary text for Guiding Principle 17 notes: "Where business enterprises have large 

numbers of entities in their value chains it may be unreasonably difficult to conduct due diligence for adverse human rights impacts 

across them all. If so, business enterprises should identify general areas where the risk of adverse human rights impacts is most 

significant." Given the G4 draft draws heavily on the UN Guiding Principles for Business and Human Rights as a key reference 

document, it would be appropriate for GRI to take into account the UN’s assessment of the challenge of reporting on impacts for 

every single supplier. 


They need to be extended upstream to the clients Business Europe Reporter 

Report Reader 

Too much Business Northern Reporter 

America GRI 

Consortium 

Member 



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We believe there should be more explanation of the importance of occuaptional safety and health in supply chain management and 

sustainability and how this can best be measured and reported. 

We believe, given the amount and nature of information required, that a more in depth guidance would be appropriate. 

We consider that some indicators could be more explicit. For instance: 

Is that possible to provide us with examples for each of the following indicators 'G4 11' and 'G4 13'? 

Since the compilation method is equivalent, we found it hard to distinguish these two indicators 

Yes in general, with caveats indicated elsewhere. It would be good though to have a summary somewhere in the guidelines for an 

organization that wants to do a separate analysis of supply chain practices as the information is scattered across the guidelines and 

difficult to piece together. It could be a summary of pages in the glossary, for example. 

Yes in general, with caveats indicated elsewhere. It would be good though to have a summary somewhere in the guidelines for an 

organization that wants to do a separate analysis of supply chain practices as the information is scattered across the guidelines and 

difficult to piece together. It could be a summary of pages in the glossary, for example. 

Yes in general, with caveats indicated elsewhere. It would be good though to have a summary somewhere in the guidelines 

for an organization that wants to do a separate analysis of supply chain practices as the information is scattered across the 

guidelines and difficult to piece together. It could be a summary of pages in the glossary, for example. 


Our members 

help 

organisations 

prepare and 

use 


reports 

Financial 

Markets & 

Information 

Users 

Mediating 

Institution 

Financial 

Markets & 

Information 

Users 

Financial 

Markets & 

Information 

Users 

Financial 

Markets & 

Information 

Users 

Europe 

Europe 

Europe 

Asia 

Europe 

Reporter 

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Consultant 

Report Reader 

Report Reader 

Report Reader 

Data provider 

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- There is a lack of references, suggested: ISO 26.000 

- The GRI G4 should deal with the question of product responsibility. 

• There is a lack of references, suggested: ISO 26.000 



• The GRI G4 should deal with the question of product responsibility. 

Additional clarification would be appreciated. 


Consultant 

Institution 

Report Reader 

As explained above Business Asia Reporter 

Comment 1: Expectation for entire supply chain to be covered is an unreasonable requirement, similar to issues raised in the value Mediating Asia 

Consultant 

chain approach of Content and Boundary 

Institution 







Institution 

Covered in earlier questions Business Asia Reporter 



















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Mediating 

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suppliers for driving sustainability in respective supplier’s organization. 














approach of Content and Boundary:- The extent to which a company / organization intends to report on supply chain should be left 






















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explained in earlier comments Business Asia Reporter 

For specific actions related to the supply chain, explain practices for: 

Mediating 

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Northern 

America 

Reporter 

Consultant 

Supplier selection; list the economic, environmental and social criteria used when selecting new suppliers; and describe how the use 

of these criteria is encouraged within the organization. 

Supplier management; explain how expectations are established and defined in contracts with suppliers to promote improvement in 

economic, environmental and social performance (including targets and objectives); how suppliers are incentivized and rewarded 

for economic, environmental and social performance; and feedback and dialogue mechanisms for suppliers. 

Here, examples of incentives would be useful. For example, longer-term contracts, pricing incentives, shared investment & returns 

from a factory energy retrofit. 

I do not understand how supply and value chain are linked in the guidelines 

I think it will be complicated for companies to provide information on how the company's can take on the responsibility of the 

complete chain, the whole chain. 

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Europe 

Latin America 

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It adds to the mass of details and confusion Business Asia Report Reader 

Academic 

missing performance indicators 


Organization 

Missing performance indicators 

Mediating 

Institution 


Academic 

research 

missing performance indicators Business Latin America Reporter 

missing performance indicators 


Institution 





Mediating 

Institution 

Europe 

Report Reader 


condition of 

membership 

Consultant 

needs to be more detailed, it isn't complete 

Mediating 

Institution 

Latin America 



Institution 

needs to be more detailed, it isn't complete Business Latin America Reporter 






Mediating 

Institution 

Latin America Consultant 

Assurance 

Provider 

provided above Business Asia Reporter 



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see above on #3 


See general comment at the end of this document. 

The entire section is inappropriate and makes g4 less than useful. 

The expectation that the entire supply chain would be covered is an unreasonable requirement, similar to issues raised in the value 

chain approach of Content and Boundary. The organization must be allowed to decide the the extent to which an organization 

intends to report on supply chain. It will help companies to focus on significant suppliers for driving sustainability in respective 

supplier’s organization 

The guidance does not include appropriate materiality criteria. 

the technical protocol should be updated to include a requirement to incorporate a risk assessment of suppliers as part of the value 

chain impact assessment in order to define the scope of the value chain. 

There are blanked requests for us to identify environmental, social, labour and human rights impacts of suppliers but no guidance 

as to how to determine which have "significant" impacts. 

There is a lack of references, suggested: ISO 26.000 

Mediating 

Institution 

Financial 

Markets & 

Information 

Users 

Mediating 

Institution 

Europe 

Europe 

Northern 

America 

Assurance 

Provider 

Report Reader 

Consultant 

proivde range 

of consulting 

services 

Consultant 


Institution 


Mediating 

Institution 

Asia 

Report Reader 

Former report 

preparer. 

Current 

Academic 


Report Reader 


America 


• The GRI G4 should deal with the question of product responsibility. 

This becomes even more difficult with multi-national operations that report on a global scale rather than by subsidiary. Especially 

the mapping of suppliers and listing of all suppliers. 

Business 

Northern 

America 

Reporter 



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Q5) Do you consider the proposed supply chain-related references appropriate and complete? 

Yes 

No, please clarify and suggest references:________________ 



47 

% of 

submissions 

answering 


further 

comments 

% of 

submissions 

offering 

comments 

73 27 



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As mentioned in response to questions 1 to 4 Business Asia Reporter 

Due to above reasons. Business Asia Reporter 

Due to reasons stated above Business Asia Reporter 

Report Reader 

Due to reasons stated above 

Mediating 

Institution 

Asia 

Consultant 

Certified 

Training 

Partner & 

Consultant on 


Reporting 

Están muy desagregadas a lo largo del texto, lo que impide tener claridad sobre lo que se pretende efectivamente reportar en Business Latin America Reporter 

relación a proveedores y contratistas,. 

For most of the new indicators there are no references, and along with existing indicators (i.e., Human Rights), do not provide Business Europe Reporter 

specific guidance such as that sought in 4 above. 

Generally appropriate Business Europe Reporter 

Hess concurs with the following response to this question submitted by IPIECA: Business Northern 

America 

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For most of the new indicators there are no references, and along with existing indicators (i.e., Human Rights), do not provide 

specific guidance such as that sought in 4 above. 

In addition to the current references offered, Ceres recommends the inclusion of two additional resources: 

• The 21st Century Corporation: The Ceres Roadmap for Sustainability: a vision and practical guide for integrating sustainability into 

the DNA of a business, with a section (P2) dedicated to outlining expectations for a sustainable supply chain. 

Civil Society 

Organization 

Northern 

America 

Report Reader 

• The Supplier Self-Assessment Questionnaire (SAQ): Building the Foundation for Sustainable Supply Chains: A tool and writable PDF 

that companies can download to use with their suppliers. It is useful for those just beginning to address sustainability issues in their 

supply chains, as well as those looking to strengthen existing supply chain engagement. 

Irrelevant for me, per my comments above. 

It is too complete in that it is too extensive. This section needs to be simplified for the companies to be realistic. 

It might be useful to have a list of references by the GRI concerning standards that can be used for suppliers selection and 

monitoring. 

Civil Society 

Organization 

Financial 

Markets & 

Information 

Users 

Financial 

Markets & 

Information 

Users 

Northern 

America 

Europe 

Europe 

Consultant 

Report Reader 

R&D in 

reporting 

Report Reader 

Reporter 

Report Reader 



Accountancy 

body 

No references are provided for many of the proposed disclosures on supply chains. 

Not many references found at the indicator level. Not sure the ILO conventions are clearly earmarked in all necessary sections. As 

mentioned no reference to supply chains impact on water (Referenced through WBCSD, WRI, CDP-Water project or UNGC-CEO 

Water mandate). 

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Not many references found at the indicator level. Not sure the ILO conventions are clearly earmarked in all necessary sections. As 

mentioned no reference to supply chains impact on water (Referenced through WBCSD, WRI, CDP-Water project or UNGC-CEO 

Water mandate). 

Not many references found at the indicator level. Not sure the ILO conventions are clearly earmarked in all necessary 

sections. As mentioned no reference to supply chains impact on water (Referenced through WBCSD, WRI, CDP-Water project 

or UNGC-CEO Water mandate). 

Financial 

Markets & 

Information 

Users 

Financial 

Markets & 

Information 

Users 

Asia 

Europe 

Report Reader 

Data provider 

Report Reader 

Over prescriptive, burdensome and don't account for level of risk. Business Northern Reporter 

America 


References need to be provided for the new indicators and more specific guidance related to boundaries and prioritization for Business Northern Reporter 

existing indicators (i.e., Human Rights). 

America 

Regarding disability, the main besides references at of international levelinitiatives, such is the as United Nation Convention on the 

Rights of Persons with Disabilities (2006). 

Civil Society 

Organization 

Europe 

It would also be advisable to provide references of some legislation about national laws, policies, strategies and initiatives that could 

be considered by organizations to support broader accountability and transparence on that particular topic, such as that covered by 

the ANED's online tool DOTCOM (http://www.disability-europe.net/dotcom) covering the the Member States of the European 

Union, its Candidate countries and other associated countries. 

The provision of such references would support also accountability and benchmarking in social and economic inclusion 

performance. 

see #1 

See #3 

see answer nr. three 

See previous comment 

Civil Society 

Organization 

Mediating 

Institution 

Mediating 

Institution 

Mediating 

Institution 

Latin America 

Africa 

Europe 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

Report Reader 

Reporter 

Consultant 

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Provider 

Report Reader 

GRI trainer 

Consultant 

Report Reader 

for academic 

purposes 

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The indicator protocals are useful. It is odd the "remediation" indicators were incorporated as supply chain developments as we 

think their intent is to share grievance mechanisms available to many parties beyond suppliers and there may be some different 

inprepretations for these new indicators - more guidance may be needed here. 

The level of detail suggested seems inconsistent with the enhanced focus on material issues. 

Business 

Mediating 

Institution 

Northern 

America 

Asia 

Assurance 

Provider 

Reporter 

Reporter 

Consultant 

Assurance 

Provider 

Report Reader 

Consultant 

The UN Global Compact – Supply Chain Sustainability Resources and Practices (http://supply-chain.unglobalcompact.org/site/index) Mediating 

Institution 

Europe 

There are few references for most of the new indicators, and the ones provided for existing indicators do not address the points Business Europe Reporter 

raised in BP’s response to question four. 

Too complex - it requests information beyond the first tier, which is in some instances (i.e., those with thousands of suppliers) Civil Society Northern Report Reader 

unrealistic. We suspect this would cause organizations to not report at all. 


Too complex - it requests information beyond the first tier, which is in some instances (i.e., those with thousands of 


suppliers) unrealistic. We suspect this would cause organizations to not report at all. 


too much granularity was introduced in the updated text. Business Northern Reporter 

America 

We would like to see inclusion of references related to occupational safety and health systems such as the 'ILO Guidelines on 

Occupational Safety and Health Management Systems, 2001'. 


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- Business Europe Reporter 

: Due to reasons stated above Business Asia Report Reader 

• Business Europe Reporter 





As said above Business Asia Reporter 




Institution 

Due to reasons cited above Business Asia Reporter 



Consultant 

Institution 




Mediating 

Institution 

Asia 

Reporter 

Report Reader 

due to reasons stated above Business Asia Report Reader 

Due to reasons stated above Business Asia Report Reader 








Mediating 

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Consultant 

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Consultant 

Institution 

Due to reasons stated above Business Asia Assurance 

Provider 

Report Reader 





Due to same reasons mentioned above Business Asia Report Reader 

Expectation for entire supply chain to be covered is an unreasonable requirement, similar to issues raised in the value chain approach Business Asia Report Reader 

of Content and Boundary:- 




For the reasons mentioned above Business Asia Report Reader 

Its not clear the boundaries refered to supply chain issues. 

Financial Latin America Reporter 

Markets & 

Information 

Users 

More information related to GURUS on Supply CHain Management, as for example, Keith Oliver, Andreas Wieland, Carl Marcus 

Wallenburg (2011): David Jacoby, Mentzer, J.T. et. al. (2001): Defining Supply Chain Management, in: Journal of Business Logistics, 

Vol. 22, No. 2, 2001, pp. 1–25, among others. 

most references are from a western perspective. NO regional/national reference applicable into an Indian context 

See above. 

See general comment at the end of this document 

The guidance does not include appropriate materiality criteria. 

Mediating 

Institution 

Mediating 

Institution 

Mediating 

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Mediating 

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Mediating 

Institution 

Latin America 

Asia 

Europe 

Northern 

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Asia 

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proivde range 

of consulting 

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This becomes even more difficult with multi-national operations that report on a global scale rather than by subsidiary. Especially the 

mapping of suppliers and listing of all suppliers. 

Business 

Northern 

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preparer. 

Current 

Academic 

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Q6) Do you have other general comments related to the Supply Chain Disclosures? 

% of total 

submissions 

answering this 

question 

33 



Relationship 

- All supplier/supply chain aspects should be covered in a separate section. This would make it easier to reduce the 

number/complexity of indicators and to improve the user friendliness of the guidelines. 

- It would make sense to combine Labor Standards & Human Rights for Suppliers instead of repeating the indicators. 


- Furthermore instead of pure relative KPIs risk-based approaches should be considered in the KPIs definition; for a company with 

more than 90.000 suppliers, risk based assessments are necessary because other approaches are to cost intensive. 

• GRI should consider to cover all supply chain-related aspects in a dedicated section of the guidelines. This would help to assess the 

total disclosure requirements related to the supply chain and, based on that, to adjust the number and granularity of 

indicators/disclosures to a more feasible level. 

• G4 should clarify that some information on supply chain partners can only be provided in “good faith” and cannot be verified 

though screenings or audits by the reporter. 

• Disclosure of payment modalities will have a negative effect on the competitive environment. 

• Also, it would make sense to combine Labor Standards & Human Rights for Suppliers instead of repeating the indicators in the 

guidelines. 

• GRI should consider to cover all supply chain-related aspects in a dedicated section of the guidelines. This would help to assess the 



• G4 should clarify that some information on supply chain partners can only be provided in “good faith” and cannot be verified 

though screenings or audits by the reporter. 



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• GRI should consider to cover all supply chain-related aspects in a dedicated section of the guidelines. This would help toassess the 



• G4 should clarifythat some information on supply chain partners can only be provided in “good faith” and cannot be verified 

though screenings or auditsby the reporter. 




guidelines. 

• Many organizations have significant supply chains. It can be quite an undertaking to try and really understand the sustainability 

impacts of an organization’s value chain. ERM suggests that GRI considers applying the materiality principle to supply chain as well, 

and encourage companies to consider all their suppliers but focus on the suppliers that are strategic to an organization’s supply 

chain. 

• The information regarding spending on suppliers in core EC6 would entail an unreasonably large amount of work for companies to 

disclose. 

• G4 3 asks about time taken to pay suppliers and involves too much detail for companies to report. 

• G4 4 will be very difficult for companies to disclose, as hundreds of standards and labels exist. The meaning of “credible and 

widely recognized” is unclear. 

• G4 7 asks about grievances and seems to speak to European organizations but may not resonate as well with companies in the 

United States. 

• The word “significant” should be kept in the core HR6 indicator language as well as in a number of other places. 

•We believe that disclosing impact along the supply chain adequately as required by G4 will not be feasible for Deutsche Bank. 

•Deutsche Bank supports Econsense’s remark that G4 should clarify that some information on supply chain partners can only be 

provided in “good faith” and cannot be verified though screenings or audits by the reporter. 

1. Since supply chain is being introduced for the first time as part of Sustainability Reporting, GRI should have approached it by going 

the development of broad guidelines that are open, flexible and not prescriptive. This should have been the first step to bring 

sustainability into the supply chain before mandating particular fixed requirements for disclosure at a later date 

2. Reporting grievances to the detail prescribed in the G4 Guidelines, as per indicators G4 7 and G4 10, can compromise on privacy 

and protection of the person who raised the grievance:- 


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1. We support the decision to treat issues relating to the supply chain as cross-cutting and would not want them to be grouped as a 

separate category. However, more could be done to simplify reporting in this area. Generally, in the G4 text, supply chain issues 

could be more logically treated as “value chain” issues or under other broad areas such as “organizational relationships” or 

“community engagement”. There should be an effort made to review supply chain text to see whether it would be more 

appropriately treated as value chain text, for example. 

3. Do you consider the proposed disclosures related to supply chain appropriate and/or complete? 

Yes. The scope of disclosures is large and contains a wide range of issues. The Guidance section also appears to contain indicators 

that appear to be asking for disclosure (as opposed to guidance on disclosure), which could prove confusing for first time reporters. 

Some clarity on the difference between the two could prove beneficial. 

4. Do you consider the proposed guidance provided to support disclosure on supply chain related issues appropriate and/or 

complete? 

Yes. The Guidelines could offer additional clarity within the guidance. For example it would be helpful to push companies on not just 

where they should be looking, but what they should be looking for. The Guidance can provide an opportunity to get to the point of 

the indicator better. 

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• Challenges. When identifying challenges in their supply chain, many companies make the decision to disengage with a particular 

supply rather than try and remedy the issue. Ceres recommends that the Guidelines offer guidance for companies trying to stay 

engaged to affect change. 

• Society. Some of the indicators concerning “society” were difficult to understand and the way they were phrased appear 

immaterial to most companies. It would be helpful to consider the business case in the language used for specific indicators. 

A reporting organization should not be responsible for reporting sustainability performance for their entire supply chain. This is not 

practical and will result in a substantial and costly reporting burden for companies with complex supply chains and a significant 

number of SMEs. 

Additional focus on the supply chain will help ensure that the report considers the company’s impacts overall. It may be more 

feasible from a reporting point of view to consider material suppliers to reduce the amount of information to be reported. 

There could also be sensitivities to how much an organization would want to disclose about their supply chain where it could be 

considered a competitive advantage and a risk to disclose. This may require consent from the suppliers; therefore G4 should 

provide an opportunity to not report certain confidential data. 

All supply chain related disclosures should be included under the same section (supply chain) instead of under sections 

EC,EN,LA,HR,SO,PR. 

Maturity levels as well as sector-specific characteristics in the supply chain management should be taken into account. E.g. the 

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requirements are too rigorous for e.g. retail companies compared to companies with fewer suppliers – percentage of all suppliers 

vs. suppliers in high-risk countries 

As with the changes on governance and remuneration, this is a massive new reporting requirement in an area in which most 

companies have not yet assigned in-depth focus. The detail of disclosure required means lots more work for reporters, and many 

may decide it's just not worth the effort. The link to the overall sustainability of an organization and some of the new Performance 

Indicator disclosures is tenuous. 

In practice, the number of reporting companies which will be able and willing to disclose at this level may be really very small. 






Comment 1 

Since supply chain is being introduced for the first time as part of Sustainability Reporting, GRI should have approached it by going 



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Reporting grievances to the detail prescribed in the G4 Guidelines, as per indicators G4 7 and G4 10, can compromise on privacy and 

protection of the person who raised the grievance 




Companies will struggle to produce this information and moving from G3.1 to G4 requirements will be overwhelming until the 

reporting processes in this area are in place Although the guidelines are not currently structured this way, from a user perspective it 

would be useful and helpful for the supply chain indicators, which understandably are split across many sections, to be placed in a 

standalone section. In our experience companies prefer to have information grouped in useful sections. A supplier section could use 

subheadings to align to environment, social etc groupings 

Cost effectiveness becomes an issue, as it will be too costly for small companies to assess all their suppliers. Similarly, large 

corporations will require large amounts of capital, both human and financial, while the purpose of it seems unclear. 

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Disclosure DI12 will not be answered by any serious company. This represents the heart of competitive advantage for most 

companies. 

Each Reportee must have the flexibility to define the scope and amount of its Supply Chain, and the related disclosures, suitable for 

the public of the report and its stakeholder 

Falta explicitar de qué modo se deben reportar los temas relacionados con proveedores y contratistas y cuál es su alcance. No se ha 

considerado a las pequeñas y medianas empresas, que constituyen la mayor cantidad de proveedores y contratistas, en el proceso 

de validar la guía para reportar, por lo que G4 corre el riesgo de transformarse en una metodología ociosa, en el sentido que va a 

tener escasa aplicación 

Good intentions, but too ambitious! 

There is a need for a gradual way to start reporting on supply chain issues, the ambitions are too high for a first time reporter. Also, 

the new aspect under Economic Performance Indicators (procurement practices p.53) makes sense, but we fear that this will be too 

ambitious and time-consuming for the reporters. 


It is a need for a graded way to start reporting on supply chain issues, the ambitions are too high for a first time reporter. 

The New aspect under Economic performance Indicators, PROCUREMENT PRACTICES (p 53): 

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I understand the idea, but I fear this will be too ambitious and time-consuming for the reporters. 


There is a need for a gradual way to start reporting on supply chain issues, the ambitions are too high for a first time reporter. Also, 

the new aspect under Economic Performance Indicators (procurement practices p.53) makes sense, but we fear that this will be too 

ambitious and time-consuming for the reporters. 

GRI should consider to cover all supply chain-related aspects in a dedicated section of the guidelines. This would help to assess the 



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G4 should clarify that some information on supply chain partners can only be provided in “good faith” and cannot be verified though 

screenings or audits by the reporter. 

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Also, it would make sense to combine Labor Standards & Human Rights for Suppliers instead of repeating the indicators in the 

guidelines. 

GRI should consider to cover all supply chain-related aspects in a dedicated section of the guidelines. This would help to assess the 



G4 should clarify that some information on supply chain partners can only be provided in “good faith” and cannot be verified though 

screenings or audits by the reporter. 

Disclosure of payment modalities will have a negative effect on the competitive environment. 


Also, it would make sense to combine Labor Standards & Human Rights for Suppliers instead of repeating the indicators in the 

guidelines. 

I believe that the increased attention on the supply chain in the G4 reporting guidelines a very good thing. 

I am concerned about the possible unintended impacts of the proposed additions. 

• Would the new reporting requirements be a burden on companies and suppliers, reducing their ability to quickly adapt to 

changing market needs? I believe so. 

• Would the new requirements squeeze out smaller, less sophisticated suppliers, and have a negative social impact? Possibly 

• Do the new requirements place an unfair burden on smaller organizations (SME)? I believe so. 

• Would these changes help or hinder the inclusion of more and more SMEs into the reporting process? Likely. Would the 

relationship between partners strengthen or not? Uncertain. 

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I feel that G4 should take a more collaborative-developmental-educational approach to the supply chain. I believe in the 

importance of encouraging adoption of sustainable management practices in the supply chain and that this would be better 

accomplished through a process of FIRST cooperation and education, and SECOND, assessment, remediation and eventually forced 

compliance. 

Overall: 

- Provide Profile Disclosures on Supply Chain, as suggested in G4 

- Provide Disclosures on Management Approach suggested by G4 which would include disclosures on Procurement Practices, 

Employment, and activities to educate and prepare supply chain partners. 

- EC6, maintain 

- G4 3, maintain 

- G4 5, G4 8, HR2, G4 12, maintain These indicators would allow for an organization to assess their suppliers and explain what is 

being done to improve overall performance. 

Why is the burden of performance being transferred from the supplier to the reporting company and would it not be better to 



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encourage suppliers to become sustainability reporters as well. In that way, suppliers would begin to understand the issues and 

benefits of a more responsible management approach. Why not have an indicator on the percentage of suppliers who provide a 

sustainability report? 

I see a distinct danger in prescribing a assessment process that is a by-product of developed economy businesses utlizing cheap 

labour abroad. For an Indian company, issue is of complying with local laws while working towards continual improvement along the 

supply chain by bringing in better standards- not spending time and money doing social impact assessments in a very resource 

(money as well as human) constrained reality. 

I think Supply Chain disclosures are an important aspect of a more material reporting. It will help companies to recognize their 

impact and to try to improve it. However, it might be a long way to get there, not only in terms of management acceptance ("why? 

we are not responsible for what they do") but also in terms of control (how to get the data, how to make sure suppliers are not 

asked about their data from their 100 customers with 100 different questionnaires). 

i. In the new “screening and assessment” section it is mentioned that data should be broken down by “the nature of the issue” – it 

would be helpful if GRI provided some examples of this. 

ii. p. 67, 847: Is it prices paid to supplier’s suppliers and the supplier’s workers or the prices that the organization pays to their 

suppliers? 

iii. p. 111-112: the definition of economic inclusion (1252-1256, p. 112) is a bit confusing (the indicator is only related to locallyowned 

suppliers – and then you can further break down the locally owned suppliers into women-owned etc, right)- would help if 

“for the purpose of this indicator” was deleted 

iv. The phrasing of all questions for CORE G4 6 (p. 179) is a bit confusing (should there be a “,” before assessed”)? 

v. It is unclear how other elements of the value chain shall be addressed. There are overall indicators, there are SC indicators, and 

there are references to “other business partners”. What this means and how it should be taken care of stays unclear. 

vi. The references that are given are appropriate, but there are not many references provided for users. Maybe other stakeholders 

who review the guidelines will suggest some additional resources. 

vii. Overall, because of all the points mentioned above, we are very concerned about the acceptance of the supply chain aspects by 

the reporters 

in banking, especially in credit card, supply chain may include merchants (for promotional and cross selling etc), in which ESG risk 

may apply but it is not manage as deeper as other business sector. 

the guideline shall incorporate also this. 

In general, I think the addition of more supply chain criteria throughout is very valuable. However, I do think there is a risk of 

repetitiveness throughout the report. In practice, I imagine many companies would continue to report on these indicators in a 

separate supply chain section to reduce repetition since the process for screening or grievance is likely going to be a single system or 

linked systems that address environmental, labor, human rights, and product responsibility topics. 

In theory, the supply chain-specific indicators are appropriate. We fear, that in real life it is not handable for the companies. How 

should a big company that does business all over the world and have some thousands of suppliers disclose all the proposed 

indictors? 

It can be quite difficult to define the value chain according to the impact criteria (and not effective control), which may difficult the 

comparison amongst organizations. 



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On the other hand, big and multinational companies would have to report with great detail about their suppliers, regardless of their 

size and relationship (long/short term). 

It is a need for a graded way to start reporting on supply chain issues, the ambitions are too high for a first time reporter. 

The New aspect under Economic performance Indicators, PROCUREMENT PRACTICES (p 53): 

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I understand the idea, but I fear this will be too ambitious and time-consuming for the reporters. 

It is a very valuable intention to include more supply chain aspects into GRI reporting. However, the present proposal of the G4 

guidelines does not provide a practical way of doing this. 

It is important to include and increase information about the value chain into sustainability reporting and to have organizations 

reflect on their respective value and supply chains. The G4 proposal is not a practical way of doing this. A mapping of the value chain 

as is also proposed in G4 is sufficient disclosure for this topic. 

It is necessary and positive to expand our look to the whole chain, however, the proposal is still confusing, with many “repeated” 

indicators or some of them are very similar. 

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We see an opportunity to better grouping indicators and broaden perspectives beyond chain performance, for instance, 

demonstrating how the company encourages the development, education and innovation in their supply chain. 

Considering that many of the proposed indicators seek to broaden the assessment of impacts in the supply chain, we understand 

that there is a great difficulty in comparability since there are different impact-assessment methodologies available, which 

depending on the depth and quality of the assessment made by the organization, may produce totally different results. 

It may be useful to consider how companies will describe the various supply chain participants and their respective roles in the 

context of the reporting company; specifically with respect to individuals entities, associations, partnerships, affiliates, and others 

organizational structures that may be useful in describing the parties. 

Line 697, 1351-1352: Report the % of total payments to suppliers that were made late. I don’t think this is a realistic measure for 

organisations that have large supplier bases – particularly in South Africa where we aim to give business to BSMEs – this means we 

will have many small companies to contend with. Is it not more relevant to determine whether there are special payment strategies 

for SMEs to enable them to manage their cash flows better? To me this would be more meaningful than late payments? 

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Line 1350: Identify the time designated, agreed or contracted to pay each supplier invoice. This is far too onerous for companies 

that have large supplier bases. 

Location of supplier is very hard to define. Some suppliers may have an adress somewere, but are working in different regions. 

Company adress does not mean that the origin of the company and its employees are at the same place. Its possible to register a 

company at different adresses, even having more that one adress. 

Number of supplier´s employees X number os organization´s employees is an interesting indicator (working directly in the 

production process). 

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Many electric utilities are actively engaged in sustainable supply chain practices, either individually or through groups such as the 

Electric Utility Industry Sustainable Supply Chain Alliance. Given the scope of the topic, clear definitions and standards are critical to 

the process of determining metrics around supply chain sustainability. To that end, we suggest that G4 integrate clearer rationale 

and definitions into its supply chain disclosure and indicators. We agree that supply chain focus is increasingly important to 

investors, customers, suppliers and other stakeholders. This is evidenced by investor-focused surveys such as the Carbon Disclosure 

Project Supply Chain and the inclusion of supply chain performance indicators in surveys and rankings done by the Dow Jones 

Sustainability Index, Bloomberg, Goldman Sachs, and others. In addition, utilities are finding themselves increasingly on the 

receiving end of these surveys from their customers to whom they supply electricity. It therefore may be appropriate that G4 

increase its focus on supply chain in light of this changing environment. 

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However, in the electric power industry, like many other industry sectors, one company could have thousands of suppliers for a 

wide range of products and services. Supply chain indicators, disclosures, governance, and reporting are not simple for any 

organization. We suggest that G4 focus the supply chain questions on the more material questions, the core issues, rather than 

asking for broad, vague, and generic information. Further, as already noted, the supply chain questions should be consolidated into 

one section that can addressed by an organizational manager overseeing suppliers. 

Maybe the supply chain related indicators could be grouped together. The majority of the companies would write about suppliers Mediating Europe 

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and related info in the same chapter. It would be easier to follow what info is needed regarding the supply chain 

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Okay confirmed with the Supply Chain Disclosures draft. 

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On page 114, under Relevance reference to high turnover is made. Some reference or definition should be provided with this for 

clarity and guidance. 

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On page 114, under Relevance reference to high turnover is made. Some reference or definition should be provided with this for 

clarity and guidance. 

On page 114, under Relevance reference to high turnover is made. Some reference or definition should be provided with this 

for clarity and guidance 

Organizations should report disability as a material issue, not only because of the inherent social risks and the governance 

challenges the supply chain poses, but also because of the many rewards it can deliver. 

There is increasing legislation favouring goods and services providers that comply with employment regulations for people with 

disabilities, or foster special measures addressed to people with disabilities, in public procurement. This tendency is growing as new 

challenges, including high public deficits, asks for a most efficient use of public money, and, at the same time for an increasing 

contribution to the achievement of overall societal goals, such as fostering innovation and promoting social inclusion, among others, 

of people with disabilities. 

Our company has thousands of suppliers, and we are in the midst of undergoing SAP, which would make answering these indicators 

easier. We are also undergoing a process to develop a Supplier Code of Conduct, supplier surveys, and supplier portal which will 

incorporate sustainability. Yet we may never be able to relay some of the information requested to this level of detail even once we 

have established all of these programs in the next few years. GRI needs to ensure that the questions are simple and are not 

requiring an army of people to respond to multiple questions asking the same thing slightly differently. 

Regarding indicators on risky geographic areas (pag. 77-78), where human rights violations could occur, the guidance doesn’t specify 

which Countries are considered to be at risk, or what reference to use in order to determine them. A guidance would be helpful, and 

a similar disclosure could be requested concerning environment and Countries which have loose environmental laws. 

Risk management and due diligences are critical to understand and foster sustainability into supply-chains. However GRI should 

defend a much more collaborative and pro-active approach, rather than mainly an intrusive & defensive approach, which could be 

harmful and misunderstood by SMEs. When implementing sustainable procurement policies, reporting organizations should be 

invited to show off the carrot (rewards, incentives, long-term partnerships, mutual trust…), and not only the stick. 

Moreover companies should be invited to consider differently the various range of suppliers (tier 1, tier 2, tier 3 etc) and the risks 

emerging from small suppliers. The spend analysis could be misleading as well: it does not matter that much to assess a supplier’s 

sustainability performance if it is a large multinational, even if it accounts for as much as 10 % of the purchasing expenses. The 

impact resulting from a human rights scandal could be as high even if the supplier accounts for 0,01 % of the purchasing expenses. 

These guidelines need to be realistic. When you operate in weak-governance countries, it is very likely that tier 1, tier 2 or tier 3 

suppliers do not fully comply with Western human rights standards. The only thing companies could do is to focus on top suppliers 

for high-risk commodities. 

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Significant and welcome improvement 



sustainability into the supply chain before mandating particular fixed requirements for disclosure at a later date. 

Some of the disclosures might be viewed as business-sensitive information and where the relevance to sustainability is unclear, eg, 

spending on suppliers with which long-term agreements exist, percentage of suppliers with which orders were placed for the first 

time during the reporting period. On the aspects of screening and assessment, and remediation, it is a good idea to divide the 

indicators into the sub-categories of labour practices and decent work, human rights, society and product responsibility. 

Supply chain information should be required taken into account feasibility of the organizations to display the information as well as 

necessary confidentiality and critical information for the brand. Suppliers are strategic for many companies and report should not 

interfere or violate competitive advantages of companies base on the suppliers election. 

Supply chain information should only be required when it is a material topic for the organisation, and in order to know this 

stakeholder engagement is key. 

Supply chain seems appropriate for mostly in manufacturing companies, while as mining companies, they do not have significant 

supply chain to be disclosed. Never mind...as long as this information is important ,keep the supply chain as a good option:) just 

maybe provide appropriate information about the different supply chain for every different industry types. 

The addition of indicators interwoven into the indicators is a good approach rather than a separate category for supply chain. 

Overall there is a concern regarding the increase resources required to undetake the additional supplier assessments. The removal 

of the word significant in front of supplier suggests that all suppliers must be assessed and this would be of significant concern to 

most reporters because of the number of suppliers and the applicability of the concepts. We would suggest a risk based approach to 

assessing suppliers e.g. those that operate in countries identified as high risk of HR issues etc. Only suppliers identified as high risk 

(replacing the concept of significant) would need to be assessed and remediated. 

The addition of supply chain disclosures is a welcome addition to the GRI that reflects a trend of extending company commitments 

to sustainability in the way they manage their supply chains. These indicators are a good move toward transparency around location 

by country, region, and materials sources. We believe this section could be improved with refinement that reduces the level of 

detail and focuses on those indicators with a direct link to sustainability. Additionally, indicators for downstream activities should be 

added to reflect the full value chain. 

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BSR recommends including these additional disclosures with additional refinement that focuses on sustainability and balances the 

number of indicators between upstream and downstream impacts. 

the additional information required on suppliers (disclosure, indicators) goes too far. The risk is that a lot of information will be 

communicated (often information on all suppliers is requested) and the material information gets lost in this mass of information. 

The aim of G4 is to streamline and shorten the reports - this will not be possible with the supply chain added. Also take care not to 

use the terminology 'supply chain' and 'value chain' interchangeably in the text as these are two different concepts 

The change in the boundary approach, which foresees the inclusion of the Supply Chain performance, should be reflected 

accordingly on the structure of other existing indicators. 

For example, indicator EN1 still refers to materials used by the organization only. In our opinion, it would be advisable to split it into 

two parts: 


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EN1.1: direct material consumption (by the organization – financial statement boundaries) 

EN1.2: indirect material consumption (by other members of the supply chain for whom this topic is material). This kind of structure, 

replicated for each indicator, would enable an effective comparability between reports of the organization over different years, or 

between reports of different organizations. Also, in the view of the transition towards integrated reporting, the sustainability 

indicators (e.g. EN1.1) would be still comparable with the financial indicators, as referred to the same boundaries. 

The supply chain disclosures and guidance are integrated throughout the GRI Guidelines and it may be useful to have an index of all 

the supply chain related information for reference purposes. 

In emerging markets the informal nature of the SME sector may present difficulties for reporters to report on their supply chain 

since they conduct business with many informal suppliers. 

The definition of "locally owned supplier" should be further described. 

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The definition currently allows each reporting company to define "local". The GRI should further define "local" as to whether this 

refers to a supplier organization located within a country or if suppliers locations are within a certain distance from a corporation's 

manufacturing operations, for example. This would allow for comparison of reporting companies utilizing the GRI G4 Guidelines. 



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It is also unclear how to define ownership for "locally owned supplier" if the company is publicly traded and ownership is spread 

across many shareholders. 

Finally, it should be noted that most corporations track the addresses of supplier headquarters, shipping locations, and/or 

distribution centers versus the owner location, which could be different. So there would be a cost for organizations to gather and 

maintain this type of data moving forward in response to this definition. 

The extent to which company / organization intends to report on supply chain should be left to the discretion of the organization. 




Also, it would be virtually impossible for conglomerates to cover the entire supply chain. This exercise may become very tedious 

without any significant value addition. 

For companies which have started sustainability reporting recently or those who wish to start, for them disclosure related to entire 

supply chain may not be attainable and will create barriers for them to disclose their performance as per triple bottom line. 


protection of the person who raised the grievance: - Disclosing details of grievances filed, by nature and location and specific party, 

may take away the confidentiality that is the essence of whistle-blower policies. Grievance reporters require protection and 

therefore, public disclosure of ‘who’ and ‘where’, by stating the type of stakeholder and consequent diversity related disclosures of 

the person does not seem appropriate. 

The insertion of new Screening and Assessment and Remediation Aspects in the Society category doesn’t seem particularly 

applicable. Specifically, asking companies to discuss “percentage of new suppliers screened for society-related performance” (lines 

1101-1102) is vague and confusing. Even if reporters consider “society-related” performance as referring to the several Aspects 

under the Society category (Local Communities, Corruption, Public Policy, Anti-Competitive Behavior, and Compliance), it is unclear 

what, exactly, is meant by (for example) “screening for local communities, or, public policy”. 

We suggest: that the GRI either remove the Screening and Assessment and Remediation aspects from the Society category OR more 

clearly define what topics the indicators G4 12, G413, and G414 are meant to cover. 

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The number of indicators have increased substantially and we will need to establish processes for collation and reporting of the 

data.The scope (locations) is increasing every year and it becomes very cumbersome if there are organizations which expand 

globally very fast. There are lot of complexities like ownership of campus (owned/leased which enable determination of scope), 

language, regulatory requirements etc., which will need to be considered before the process is implemented and/or modified based 

on these complexities and data for establishment of baseline is required. Hence it is suggested that a 2 year transition period is 

allowed for old reporters also. 


Report Reader 

The proposed changes in G4 appear to assume that all companies should map their entire supply chain in all cases, yet the reality is 

that companies need to prioritize their attention to high-risk countries and issues. Mapping entire supply chains just for the sake of 

mapping would not be relevant or appropriate and would divert huge amounts of resources away from higher priority activities. 

Mapping supply chains deep into a low-risk country would not be useful for many companies since they are unlikely to find many 

priority issues. Instead, companies should focus on high-risk countries and high-risk issues as the highest priority, which is the 

approach taken in the UN Guiding Principles on Business and Human Rights. 




The required information for supply chain is very complex. Specifically removing the word “significant” from the definition of 

suppliers has tremendous impact on organiza-tion’s reporting. This change is contradictory to the objective of contributing to more 

rele-vant sustainability report. By reporting on all suppliers without prioritization will result in unduly lengthy and repetitive reports. 

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In general we agree that the structure of the supply chain section. However, the threshold will be set very high for existing as well as 

new reporting organizations. GRI should think of a phasing in solution to give organizations more time to collect data (see also 

comments on Application Levels). 

The value chain is relatively new in this guide and it is very relevant to give a more important place on G4, as it has a great impact in 

the sustainability and ethics of any business. It would be interesting trying to connect a few more concepts and indicators to guide 

the management of the Value Chain Global Compact, as it offers also interesting notions of how to work and develop the value 

chain in business. 

There is still some lack of guidance on selection of relevant suppliers. Assessing 100% of the companies’ suppliers is not feasible. 

Many supply chain indicators like Core G4 3 also seem to be critical to report for competitive reasons. 

There might be an opportunity for GRI to: 

o Be clearer on the scope of the supply chain it expects companies to report on 

o Specifically request information on vulnerable workers (e.g. migrant workers, women are usually the most negatively impacted by 

company operations ) 

o Ask more questions about how companies are managing poor auditing standards and bribery & corruption of auditors – it’s a 

massive issue in the labour standards world and improved company disclosure will help draw attention to it 


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o Strengthen information requested on remediation of supply chain issues found and how companies are supporting suppliers to 

resolve issues 

These are clearly some of the areas of most profound change. Caution is therefore urged. Structurally, it takes considerable effort 

to understand the hierarchy from general to to specific disclosure and therefore how considerations of materiality are factored in 

the select of detail and level of focus. Taken to its fullest, there is potentially a proliferation of data without a clear understanding of 

where and how behaviour is shaped. The central point MAY be at the DM&A and Procurment Practice level, but this is not apparent. 

In these terms the Part 4 Technical Protocol wooks in well with the Guidelines generally, but less so when it comes to determining 

what supply chain material ought be disclosed. Likewise the Screening, Assessment and Remediation disclosures will for some 

entities be very important, though the criteria for their use should be made more clear, otherwise there is risk of volume of 

disclosure withour real gain. 

This is a changing definition depending on how far the company looks up and down its value chain. The text provides flexibility to 

adapt to the varying viewpoints of companies. 

This is a welcome development to include indicators on the supply chain. It should be much clearer what the difference is between 

the “value chain” and the “supply chain” as mentioned earlier. One general way that the indicators could be improved would be to 

account for opportunities rather than simply covering risk monitoring. A more holistic view of the supply chain including both 

inbound and outbound logistics should lead companies to recognize the supply chain as a key source for improving not only their 

environmental impacts by working with suppliers but also cost-savings opportunities through more efficient environmental 

practices throughout their entire supply chains. 


Advocacy and 

research 

Mediating 

Institution 

Financial 

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Information 

Users 

Northern 

America 

Europe 

Consultant 

Report Reader 

Report Reader 

More specifically, there are some details in the indicators that are unnecessary and would likely provide more burden on the 

companies than benefits for the end-users of the data. Core G4 3 should be deleted for this reason (the results are unlikely to be 

meaningful). The indicators relating to screening and assessment are important, but they should be simplified. Core G4 6 needs to 

be significantly simplified / clarified. The terms “society-related” is extremely vague in indicators Core G4 12-14 and should be 

clarified and / or clearly defined. 

There are several instances where the difference between short and long-term supplier relationships is emphasized under the 

assumption that long-term relationships are more sustainable. However, many of these differences will be driven more by the 

nature of the industry, sector and business model rather tan anything having to do with sustainability performance. Rather tan 

focusing on the length of the supplier relationship, the issue can and should be addressed more directly by asking companies to 

disclose information about the content of their ESG supplier policies as well as programs that may exist to educate and train their 

suppliers on sustainability issues. While the screening and assessment indicators are important, they should be consolidated and 

shortened in order for answers to be more focused on the most essential aspects of sustainability performance. 

Too granular. Too complex for companies to practically report on. Business Northern 

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We believe that are two types of issues in agreement with the supply chain information. On one hand, there is information on issues 

that a company can impact on their suppliers, but it also can control them. On the other hand, there are issues that a company can 

induce, but can not control. An evaluation on this matter must be individual (for each supplier). 

What are the limits on the supplier's matters that define what should a company report and what should be the supplier's task to 

report? Or should be reported in both reports every time there is that opportunity? 

We believe that GRI considered it was necessary to increase the degree of relevance and the weight of supply chain within the 

guidelines. However it seems like different people has been working in different parts of the guide, because supply chain is mixed 

and in some points repeated. It might be clearer to consider all the screening and assesment aspects as a whole, under the category 

of supply chain or related with the procurement practices in order to avoid duplicities. For example, the screening and assesment in 

the area of Human rights is totally duplicated with the screening and assessments of the other categories and the indicators HR5, 

HR6 and HR7. 

We fully support the inclusion of improved indicators to measure occupational safety and health working conditions in supply 

chains. We believe workers for suppliers in the developing world can be especially vulnerable to occupational safety and health 

risks. This can be for a combination of reasons including weak governmental regulation; poor management systems; lack of 

enforcement by governments or oversight by the corporations that purchase products or services from the suppliers; less educated 

and sometimes illiterate workers; and inadequate training and supervision. Basic safety and health measures and investments are 

often bypassed, and employees frequently lack the basic knowledge required to be proactive about their own safety. Corporations 

that source products from developing countries are well positioned to provide oversight and support for their suppliers to ensure 

the safety, health, and well-being of supplier workers. 

Mediating 

Institution 

Mediating 

Institution 

Europe 

Europe 

Consultant 

Report Reader 

Reporter 

Consultant 

Report Reader 


Our members 

help 

organisations 

prepare and 

use 


reports 

As a co-founder of the Center for Safety and Health Sustainability (CSHS), IOSH would encourage reporters to audit their suppliers, 

thereby helping to promote proactive health and safety measures and saving lives in the long run. 

We have a number of concerns related to the indicators requesting information on grievances. Please see specific comments in 

Document Review Section. 














America 

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We have a number of concerns related to the indicators requesting information on grievances. Please see specific comments in the 




We in general agree that disclosure on supply chain is important, but GRI needs to take into account how the casual use of the 

word “all” may be misinterpreted if direct reference back to the what is material or not, is not prominent or obvious. Please refer to 

comments given under question 2 of this section. 

We suggest that the proposed disclosures are too extensive and do not focus on the material impacts. They may be “best practice” 

but are way ahead of their time for many countries and organizations. While this may be seen as a driver for further improving 

sustainability management for some advanced companies, companies which are less mature in their approach to sustainability 

might be daunted by some of the indicators (e.g. screening and assessment) 


Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 


America 


America 



America 



Mediating 

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Europe 

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Assurance 

Provider 

Considering the importance of supply chain management to sustainability, it would be a disadvantage to push for everything and 

get nothing, in other words to risk turning this “potential driver” into a “reporting disincentive”. 

We support efforts to expand the supply chain disclosures to include procurement practices, screening/assessments and 

remediation. However, I think these new core disclosures (G1-4) will be very difficult and burdensome for companies with complex 

supply chains to manage. This adds a layer of complexity to reporting and may make it difficult to be "in accordance" with the GRI. 

The importance of better indicators geared toward improving conditions in the supply chain cannot be overstated. Workers for 

suppliers in the developing world are especially vulnerable to occupational safety and health risks. This is a function of weak 

governmental regulation, poor management systems, lack of enforcement by governments or oversight by the corporations that 

purchase products or services from the suppliers, less educated and sometimes illiterate workers, and inadequate training and 

supervision. Basic safety and health measures and investments are often bypassed, and employees frequently lack the basic 

knowledge required to be proactive about their own safety. The ILO has reported that the work-related mortality rate in developing 

countries is five to seven times higher than in industrialized nations. ILO research also found that while accidents and illnesses are 

decreasing in the developed world, both are increasing in the developing world. 

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Corporations that source products from developing countries are well positioned to provide oversight and support for their 

suppliers to ensure the safety, health, and well-being of supplier workers. The indicators proposed by the Center for Safety and 

Health Sustainability would encourage reporters to audit their suppliers, thereby helping to promote proactive safety measures and 

saving lives in the long run. 

We support efforts to expand the supply chain disclosures to include procurement practices, screening/assessments and 

remediation. However, I think these new core disclosures (G1-4) will be very difficult and burdensome for companies with complex 

supply chains to manage. This adds a layer of complexity to reporting and may make it difficult to be "in accordance" with the GRI. 

The importance of better indicators geared toward improving conditions in the supply chain cannot be overstated. Workers for 

suppliers in the developing world are especially vulnerable to occupational safety and health risks. This is a function of weak 

governmental regulation, poor management systems, lack of enforcement by governments or oversight by the corporations that 

purchase products or services from the suppliers, less educated and sometimes illiterate workers, and inadequate training and 

supervision. Basic safety and health measures and investments are often bypassed, and employees frequently lack the basic 

knowledge required to be proactive about their own safety. The ILO has reported that the work-related mortality rate in developing 

countries is five to seven times higher than in industrialized nations. ILO research also found that while accidents and illnesses are 

decreasing in the developed world, both are increasing in the developing world. 

Corporations that source products from developing countries are well positioned to provide oversight and support for their 

suppliers to ensure the safety, health, and well-being of supplier workers. The indicators proposed by the Center for Safety and 

Health Sustainability would encourage reporters to audit their suppliers, thereby helping to promote proactive safety measures and 

saving lives in the long run. 

We want business to change and recognise the supply chain and SME's. What is proposed will be hard to implement but GRI should 

stick with it as there are many companies that exist and already display these levels of knowledge on their supply chain. 

Why has "significant" been removed as a modifier for "supplier"? Surely it is not proposed that we review all of our >10,000 

suppliers for materiality? 

Civil Society 

Organization 

Mediating 

Institution 

Business 

Northern 

America 

Europe 

Northern 

America 

Report Reader 

Reporter 

Consultant 

Report Reader 

GRI Certified 

Training 

Partner 

Reporter 

Also, we have a number of concerns related to the indicators requesting information on grievances. Please see specific comments 

in Document Review Section. 

Worker Health as defined more broadly than occupational health and safety or concern about “serious diseases.” Possible new 

indicators include the percentage of workers that have access to onsite health professional trained in prevention and diseases; the 

number of major suppliers that have health clinics and/or health providers on site. Human rights language does not address 

accepted human rights standards that are in the Convention on Ending Discrimination on Women in all forms. 

Yes. Since the Draft G4 Guidance implies detailed information disclosure on an organization’s supply chain management, I believe it 

rational providing an option to disclose most of information on significant suppliers, not on all of them. 

Business 

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1. Since supply chain is being introduced for the first time as part of Sustainability Reporting, GRI should have approached it by 

going the development of broad guidelines that are open, flexible and not prescriptive. This should have been the first step to bring 



Provider 

Report Reader 

2. Disclosing details of grievances filed, by nature and location and specific party, may take away the confidentiality that is the 

essence of whistleblower policies. Grievance reporters require protection and therefore, public disclosure of ‘who’ and ‘where’, by 

stating the type of stakeholder and consequent diversity related disclosures of the person does not seem appropriate. 

1. General: 

-Many indicators don't present anymore the expression ""significant suppliers"". It is not clear whether the companies must report 

about the totality of their suppliers or only the most material ones. Specialy for large companies is difficult to report issues 

regarding all supply chain and attend some information as social and environmental criteria for contract and guidances on 

management approach. 

2. Indicators: 

DI 11 - Shall be specified when such events must be reported, considering that the supplyn chain for some companies are big and 

often suffer changes, what makes its report very complex and difficult 

DI 12 - ""The total number of suppliers"" is virtually impossible to be reported by large companies. It's a very dynamic data that 

changes every moment. It's not clear if it is expected for ""the total number of suppliers"" the data in December 31st or all suppliers 

during the reported period. The text may be ""The total number of suppliers or significant suppliers"". 

Core G4.2 (line 689) - For large companies with extensive supply chain, it´s better to specify what kind of purchase need to be 

reported. In this case we suggest only to consider the critical itens for operations and 

processes. 

Environmental DMA - Disclousure on management approach - Remediation (line 738) - In this case it shall 

be clearly pointed if it refers to workforce or if it also includes communities and other stakeholders 

Core G 4.5 (line 1406 and 1417) - I suggest that shall be considered only suppliers related to critical inputs 

ADD G4 4 - (line 698) - Another difficult item to report considering a broad supply chain. 

'1. General: 

-Many indicators don't present anymore the expression "significant suppliers". It is not clear whether the companies must report 





Report Reader 





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DI 12 - "The total number of suppliers" is virtually impossible to be reported by large companies. It's a very dynamic data that 

changes every moment. It's not clear if it is expected for "the total number of suppliers" the data in December 31st or all suppliers 

during the reported period. The text may be "The total number of suppliers or significant suppliers". 


reported. In this case we suggest only to consider the critical itens for operations and processes. 




ADD G4 4 - (line 698) - Another difficult item to report considering a broad supply chain 

'1. General: 

-Many indicators don't present anymore the expression "significant suppliers". It is not clear whether the companies must report 




Financial 

Markets & 

Information 

Users 

Latin America 

Reporter 




DI 12 - "The total number of suppliers" is virtually impossible to be reported by large companies. It's a very dynamic data that 

changes every moment. It's not clear if it is expected for "the total number of suppliers" the data in December 31st or all suppliers 

during the reported period. The text may be "The total number of suppliers or significant suppliers". 


reported. In this case we suggest only to consider the critical itens for operations and processes. 




ADD G4 4 - (line 698) - Another difficult item to report considering a broad supply chain 













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and protection of the person who raised the grievance:- Disclosing details of grievances filed, by nature and location and specific 

party, may take away the confidentiality that is the essence of whistleblower policies. Grievance reporters require protection and 


















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sustainability into the supply chain before mandating particular fixed requirements for disclosure at a later date. 







1. Since supply chain is being introduced for the first time as part of Sustainability Reporting, what was required was development 

of broad guidelines that are open, flexible and not prescriptive. This would help bring sustainability into the supply chain before 

mandating particular fixed requirements for disclosure in the future 


2. Disclosing details of grievances filed, by nature, location and specific party, may take away the confidentiality that is the essence 



As explained, I fear the bar has been raised too much too quickly. Business Europe Reporter 

As per first comment, GHG protocol gives clearer guidance which may be easier to interpret and allow comparability between Business Oceania Reporter 

reports. 

As said : too complicated, too much information, too many repetitions Business Asia Report Reader 

Academic 











Comment 1 




Comment 2 


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the type of stakeholder and consequent diversity related disclosures of the person does not seem appropriate 

Comment 1 




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Comment 2 






Comment 1 




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Comment 1 




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Comment 1 




Mediating 

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Comment 2 


protection of the person who raised the grievance. Disclosing details of grievances filed, by nature and location and specific party, 

may take away the confidentiality that is the essence of whistleblower policies. Grievance reporters require protection and 






Institution 

GRI has to keep this topic always on the dashboard Business Asia Reporter 

Having supply chain as a topic is extremely necessary, innovative, and relevant. Overall the G4 makes it harder for companies to Civil Society Latin America Reporter 

want to start reporting. 

Organization 

I do feel standard terms for suppliers should be published in the report, and if such terms to suppliers vary across geographies, then 

the changes in terms should be listed with an explanation as to why. Additionally, against late payments: an explanation as to the 

percentage of late payments, in general terms, should be noted. Is it poor communications, poor invoicing, poor supply chain 

management? Late payments to suppliers can have a major negative economic impact to the the supply company concerned. 

I find SC disclosures very focused on large scale companies, even on MNEs. I find it hard that SMEs, large size entities in some 

sectors and geographies and comglomerates could report SC indicators fully. It would cost a lot to report on these indicators. I am 

afraid this approach is more likely to discourage most entities to use G4 rather than provoking them to increase their practices 

I suggest for the board observed the references that result in important comments in the IFAC, great project: 

http://www.ifac.org/news-events?tag=83 and http://www.ifac.org/news-events?tag=85 

I support efforts to expand the supply chain disclosures to include procurement practices, screening/assessments and remediation. 

However, I think these new core disclosures (G1-4) will be very difficult and burdensome for companies with complex supply chains 

to manage. This adds a layer of complexity to reporting and may make it difficult to be "in accordance" the GRI. 

In general the G4 increases the challenges for companies to use GRI, however having supply chain now it is innovative, relevant and 

necessary. 


necessary. 

Mediating 

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necessary. 


necessary. 

In modern society, more and more companies have begun to fulfill their corporate social responsibility commitment extends to 

suppliers from the subsidiary. This is not only because of the implementation of this commitment can circumvent the supply chain 

enterprises may produce social and environmental risks and regulatory difficulties, but also because of the sustainable development 

of the supply chain can bring endless benefits for enterprises. In fact, both corporate and social, a successful continuity of supply 

chain management can become a powerful driver of value and success. Therefore, it will be a good corporate action in the global 

spread apart and it will develop a huge market summed potential and stimulate the sustainable development of the power. 

However, for many businesses, how the four key areas of the Global Compact, human rights, labor standards, environment and anticorruption, 

persistent supply into developmentchain planning is still a huge challenge. Developing a practical book which list the 

appropriate rules to choose the sustainable supply chain may help to the pursuit of sustainable development, and provide a lot of 

practical advice to deal with the challenges, to help enterprises to establish continuing with the values and principles. Exploring a 

large number of cases of good corporate action will effectively guide the enterprises to carry out a focused action towards sustained 

progress and development planning decisions. I hope more enterprises to embark on the development of a better journey to 

sustainable development of the supply chain, while firm and lasting commercial interests, but also contribute to good social and 

environmental harmony. I hope to bring about the fairer hair sustainable development work environment is the place all the 

corporate environment and the market through the following form: 

• sustainable development extends to small and medium-sized enterprises 

• Contact major social ring Yee problems of developing countries to create better links 


Institution 

student 


Mediating 

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Oceania 

Report Reader 

STUDENT 

GROUP 

ASSIAGNMENT 

FOR 

MACQUARIE 

UNIVERSITY 

AUSTRALIA 

ACCG 260 

GROUP 

• good governance and business ethics are necessary to support the development of excellent operation of commercial market 

Indicador G4 3 could be focused on small suppliers, whom time taken to pay can influence directly on their social and environmental 

performance. 

Indicadors related to social and environmental screen process, by reporting organization, and those identified as having an actual 

adverse impact, should be answered in the same indicator. By this way could let the GRI structure more clear. 

It is appropriate, but too much disclosure of supplier's information will create a loss for the company, in markets of high 

competition, high bargaining power, small scale and bandwidth issues of supplier. But it is beneficial in long run, where the market 

and such material issues reach maturity. 

It is important in the Guidance to be clear that "Performance Criteria" covers selection & evaluation criteria in sourcing and ongoing 

supply chain management. What is also important - not sure where this is covered - is quantified evidence / forms of supplier 

collaboration (eg education, training in new standards, knowledge exchange in design innovation) - some manufacturers eg have 

annual supplier forums to discuss common issues. 

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lt be taken into consideration, when applicable, the factor of the life cycle of products, as a criteria to supplier selection. It should 

also be taken into consideration the pay increase in the area where the suppliers come from. 

Maybe there could be a nudge towards laying open the list of suppliers and sub-suppliers to a specific or general public. Or an 

information requirement, how this question is handled of the company. 

My only qualmn about supply chain guidance is that it is pretty much scatterred all over the document. 

No 

no commet 

none 

Obsessive attention to governance (as defined by developed country experiences) and labour & human rights which seem to have 

been shaped by experiences of countries with global supply chains, where the disconnect happens. For Indian companies with 

national supply chains, subject to same laws and regulations on these aspects, issue is of supporting government initiatives without 

assuming government’s regulatory role. 

Obtaining information can be a costly exercise to businesses, as they are required to break down the supplier by region and 

location. Businesses are asked to report on average the number of days taken to pay suppliers as well gather data and reports. The 

effort required to prepare these reports must be measured against the actual benefit the reports will provide the business. It is 

important to note that there should be a clear incentive and or/benefits must be given to entice more businesses to produce 

transparent reports that help both the business and the global reporting organisation. 

Organizations conducting Environment, Health & Safety (EHS) Audit periodically shall be acknowledged. Performance on regular EHS 

(ensuring same through-out the supply chain, where ever applicable) evaluation shall come up as a separate core Indicator. 

Organize references in accordance to each country´s legislation, complementing international references. 


Civil Society 

Organization 

Europe 

Report Reader 

Mediating Oceania Report Reader 

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Non reporter 


Consultant 

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Lecturing/acad 

emics 

Mediating Africa 

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Mediating 

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Oceania 

Asia 

Latin America 

Report Reader 

Reading 

reports for 

educational 

purposes 

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Provider 

Report Reader 

Report Reader 

researcher on 


topics 

Report Reader 

academic 

Organize references in accordance to legislation of each country to complement the international references 

Mediating Latin America 

Institution 

Organize references in accordance to legislation of each country, to compliment international references. Business Latin America Reporter 

Organize references in accordance with legislation from each country to compliment international references. 

Mediating 

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Organize references in accordance with legislation from each country, to compliment international references Business Latin America Reporter 

Organize references in accordance with the legislation of each country to compliment international references 

Overall, the G4 makes it more difficult for companies to report and specially creates a challenge to those that are thinking of starting 

to report. However, having supply chain is innovative, relevant and necessary. 

PLEASE Consider that in LATIN AMERICA, this will be a huge effort for companies, that are trying to assume first their own 

responsibility! And GRI is pushing them to assume the responsibility of the whole chain, and compilate the information of the whole 

chain. This will automatically, in my view, generate two effects: more consultants surroundings companies efforts to report (with 

consequences on expenses, outsourcing and others) and besides, the desincentivation of companies to report and use GRI. 


See comments made on scope and type reporting under 'other' comments. 





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Former report 

preparer. 

Current 

Academic 


In developing countries where supply chain often is small and medium enterprises , all the requirements are not feasible to meet. 




strengthen the link between supply chain mapping, impact/risk assessment, materiality and boundary for supply chain reporting to 

the effect that reporters are not expected to report on the supply chain performance of their entire supplier base but where 

impacts/risks are material. 

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Streamline to management approaches for strategic influence along supply chain. 

The data surrounding supply chains involves a LOT of reliance on other entities to provide data ad could possibly result in double 

reporting and errors. To complicated, potentially putting companies 'off' reporting according to the GRI. 

The extent of disclosure required may not be appropriate in an Indian context and may scare reporters off. In addition there are a 

lot of informal suppliers which can not really be educated easily about the importance of certain indicators. (lack of maturity, lack of 

awareness) 

Mediating 

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Also, the structure of the section is quite disorganised without any logical sequence between the different indicators/paragraphs etc 








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The G4 Guidelines related to Supply Chain Disclosures are very well-crafted. They promote a genuine self-examination of issues that 

may not yet be on the organizational radar, particularly insofar as they go beyond environmental impact. I applaud this effort and 

feel certain that it can only benefit those who are not able or willing to voice issues of parity and equity with the hand that feeds 

them. 

The report should include a description of the organizations value chain 

Mediating 

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Instrutor das 

Oficinas 

Certificadas 

GRI 

The revised defination may be replaced in the Glossary. Business Asia Reporter 

Assurance 

Provider 

Report Reader 

Assurer 


std., ISO-14064 


ISO-14001 Lead 

auditor 

The Supply Chain Disclosure already proposed definitions of “supply chain” and “supplier” appropriate and complete, as it states 

that the statement should present the overall vision and strategy for the short-term, medium-term and long-term, and related to 

economic, environmental and social topic. And it gives the guidance for the forms of economic inclusion may include but are not 

limited to, andThe procurement practices that affect suppliers’ performance may include but are not limited to. And it also 

summary the aspect detailed to related supply chain to the economic, environmental and social topic. So I think the changes in 

Supply chain part is already perfect. 

The supply chain disclosures would be better set in the context of sustainable procurement, which requires an integrated 

consideration of the three aspects of SD, and for conflicts to be resolved, managed or mitigated. 

The supply chain indicators seem to encapsulate relevant detail, and clearly identify the parties to be incorporated in the report. 

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The supply chain section was very thorough. However, at times the applicability is a bit confusing. e.g. total number of grievances 

against my company or against my supplier(s)? 

The technical protocol is well articulated and is a good ‘suggestion’ for organizations to identify their unique sustainability context. 

However, it seems disconnected from the indicators which are very specific in nature and appear prescriptive, which negates the 

flexibility of the technical protocol. 

There should be a boundary defined based on the significant impacts. 

These disclosures are very detailed and not all are completely essential. Most companies especially large complex businesses will be 

very challenged to respond to all the sc disclosures at this level of detail 

Too broad brush - it might make sense for Nike to examine in detail their suppy chain, but our supply chain includes companies 

much larger than us for which we are small purchasers and it doesn't make sense to require us to do the same analysis of them. (I 

do agree with the local supplier data elements) 


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8.4 DOCUMENT REVIEW: SUPPLY CHAIN FEEDBACK 

HOW TO NAVIGATE THIS SECTION 

On the GRI Consultation Platform, the public had the option of providing specific comments on the text of the G4 Exposure Draft through a document review functionality. 

The public could select portions of the text and attach a comment. They could specify whether the comment was a content comment or a wording comment. 

The following section contains the feedback received through the document review functionality for this particular content area. The feedback is presented in tables and is 

organized by page number and line number. The tables can be read in the following manner: 


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14 

5 to do so, the report __must __ include: 1. All of the 

must 

Replace 

Content Comment 

"Shall" 

Context/ rational: To be in line with the International standard (ISO and WRI/WBCSD, etc.) and “In accordance” requirements. 

The content outlined in red can be interpreted in the following manner: 


Assurance Provider 

Report Reader 

Assurer 

On page 14, line 5 of the G4 Exposure Draft, replace “must” with “shall”, to be in line with the International standard (ISO and WRI/WBCSD, etc.) and “In accordance” 

requirements. 

The table below provides a breakdown of what the content on each line represents: 

Comment Line Key 

14 Line 1 Page No 

5 to do so, the report __must __ include: 1. All of the Line 2 G4 Exposure Draft Line Numbering + surrounding text from the G4 Exposure 

Draft 

must Line 3 The G4 Exposure text that was marked up (highlighted, replace, insert) 

Replace Line 4 The mark up action (Comment, Replace, Insert) 

Content Comment Line 5 Chosen tag 

"Shall" 

Context/ rational: To be in line with the International standard (ISO and WRI/WBCSD, etc.) and “In 

accordance” requirements. 

Line 6 Respondent comment 



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26 

81 __key __ challenges associated with performance impacts 

key 

Comment 


Consider insertion of word "significant" before impacts 

26 

81 __key challenges __ associated with performance impacts of 

key challenges 

Comment 

Wording Comment 

Why did you delete the "key challenges"? If an organization is aware of its "key challenges" doesn´t that show that the organization 

is capable of self-reflection and has therefore undergone an intensive process of self evaluation on issues of sustainability? 

26 

82 challenges associated with performance impacts __of the __ organization. This includes impacts it 

of the 

Comment 


Not only "of" but also "on the organization" 

26 

82 key challenges associated with performance __impacts __ of the organization. This includes 

impacts 

Comment 


I wonder how this works out: the bullets are exactly the subjects in our annual report. It is not possible to have 1 CEO statement 

that includes the same subjects. In the foreword the CEO addresses some subjects but if the CEO will addresses them all, the rest of 

the report will not be necessary anymore. 

26 

82-83 __impacts of the organization. This includes impacts it causes, contribu... 

impacts of the organization. This includes impacts it causes, contributes to, or that can be linked to its activities 

Comment 


The list of issues to include in the CEO statement is far too specific. This will result in a compliance type of statement rather than 

inspiring, high level statements. Unclear why "awards" etc must be part of the CEO statement. 


Mediating 

Institution 

Mediating 

Institution 

Europe 

Europe 

Consultant 

Report Reader 

for academic 

purposes 

Consultant 

Assurance 

Provider 





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26 

82-84 __This includes impacts it causes, contributes to, or that can be linked... 

This includes impacts it causes, contributes to, or that can be linked to its activities as a result of relationships with others (e.g., 

suppliers, people or organizations in local communities). 

Replace 


This includes impacts it causes, contributes to (E.G. SOCIAL AND ECONOMIC INCLUSION) or that can be linked to its activities as a 

result of relationships with others (e.g., suppliers, people or organizations in local communities). 

RATIONALE: 

Among the impacts organizations could “contributes to” it could be referred the social and economic inclusion of people with 

disabilities. 

Disability as a material topic should be evaluated among the strategic priorities an organization drives, considering different issues 

linked to disability (employment, accessibility, relationship with customers / etc.) It is important to remember that sustainability 

and social cohesion are necessarily linked. There is an increasing body of regulation regarding non-discrimination and equal 

opportunities, as well as an increasing request from stakeholders to organizations to comply with human rights. 

Civil Society 

Organization 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

The inclusion of Disability as a material topic in the strategy of the organization demonstrates engagement with a relevant 

stakeholder group, and is an absolute catalyst to progress in the integration of the people with disabilities in work, or accessibility 

performance, or to identify opportunities linked to the provision of services or products that respond to the needs of people with 

disabilities, a relevant niche for market development 

26 


impacts of the organization. This includes impacts it causes, contributes to, or that can be linked to its activities as a result of 

relationships with others (e.g., suppliers, people or organizations in local communities). 

Comment 


The CEO statement has to present the overall vision and strategy of an organisation. It is usually not designed to include detailed 

information on specific aspects. 

26 


impacts of the organization. This includes impacts it causes, contributes to, or that can be linked to its activities as a result of 

relationships with others (e.g., suppliers, people or organizations in local communities). 

Comment 


Please specify: the depth of evaluation needs to be defined more precisely; this will have an impact on the amount of data and the 

possibility to evaluate the data. 





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26 

83 organization. This includes impacts it __causes, __ contributes to, or that can 

causes, 

Comment 


• DI 1 (p. 26, line 82 ff) 

o The required depth of supply chain should be clarified in a concise manner. In most cases, tier one suppliers should be 

appropriate. 

26 

83-84 result of relationships with others __(e.g., suppliers, people or organizations in local communities).__ 

(e.g., suppliers, people or organizations in local communities). 

Comment 


(e.g., suppliers, people or organizations and public administration in local communities) 


Mediating 

Institution 

Latin america 

Consultant 

Rationale: Many countries have municipalities and districts with high influence on community decision-making processes 

26 

84 of relationships with others (e.g., __suppliers, __ people or organizations in local 

suppliers, 

Comment 


The required depth of supply chain should be clarified in a concise manner. In most cases, tier one suppliers should be appropriate. 

26 

84 people or organizations in local __communities).__ 

communities). 

Comment 


A reference should be made here to governance issues and how they are managed 

27 

85-86 __The reporting organization should indicate the nature of its role in p... 

The reporting organization should indicate the nature of its role in providing these products and 

services, and the degree to which it utilizes outsourcing. 

Comment 


Please specify: what is meant by "Primary brands, products, and/or services" - this is important since DI 12 refers to this definition as 

the basis for supply chain disclosures. 

28 

90 or __or supply chain __ and and 3. The location 


Business Oceania Consultant 

Assurance 

Provider 





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or supply chain 

Comment 


Three major concerns regarding the inclusion of the term "supply chain" 

1. The definition of "significant changes" in the supply chain is not clear 

2. globally operating companies with highly complex value chains and a huge amount of first tier suppliers will simply not be able to 

report on location, changes in relationships and selection and termination of suppliers 

3. Due to competitive reasons, it would in some specific areas (eg. raw material procurement) not be possible to disclose location or 

even name of suppliers 

28 



Comment 


"significant" needs to be defined. 

28 



Comment 


Disclosing the requested information on suppliers on an annual basis would be impossible for a global organization to fulfil in a cost 

effective and meaningful way and could also present liability issues for the reporter. 

28 



Comment 


Supply chain related to too many parts of G4, that is why it is very difficult to see it is a whole. In each case it will be very hard work 

to collect all the data. 

28 

90 or or __supply __ chain and and 3. The 

supply 

Comment 




28 

90 or or __supply chain __ and and 3. The location 



Civil Society 

Organization 

Europe 

Assurance 

Provider 


Mediating 

Institution 

Europe 

Reporter 

Consultant 



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supply chain 

Comment 


I'm of the opinion that a company, taking into coinsideration the requirements of its stakeholders should decide what information if 

any it needs to report regarding its 'supply chain' I feel 'supply chain' should not be included here. 

28 

90-96 or __or supply chain and and 

3. The location of __ suppliers, or changes in relationships 

or supply chain and and 

Assurance 

Provider 


3. The location of 

Comment 




28 

90-97 __or or supply chain and and 


3. The location of suppliers, or changes ... 

or or supply chain and and 

3. The location of suppliers, or changes in relationships with suppliers, including selection and 

termination 

Replace 




28 

90-97 __or supply chain and and 

Mediating 

Institution 

Europe 

Reporter 

Report Reader 

3. The location of suppliers, or changes in ... 



termination 

Comment 




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28 





termination 

Comment 




28 





Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 



termination 

Comment 




28 

93-97 __and and 


3. The location of suppliers, or changes in relationships wi... 

and and 


termination 

Comment 






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28 

96 and 3. The location of __suppliers, __ or changes in relationships with 

suppliers, 

Comment 


and service providers 

28 

96 of suppliers, or changes in __relationships __ with suppliers, including selection and 

relationships 

Comment 


DI 11, bullet #3 – this point is asking for three specific pieces of information that as currently written could result in reporters only 

partially reporting against these requirements. It is recommended that this disclosure point is broken into its sub components. 

It may be inappropriate and commercially sensitive for reporters to provide information on the change in relationships with 

suppliers including selection and termination and hence, it is recommended that this sub component of the disclosure is removed. 

28 

96 relationships with suppliers, including selection __and __ termination 

and 

Comment 


Vale recognizes that value chain perspective is very important to address sustainability impacts but the reporting organizations may 

face difficulties to obtain data from other companies from the value chain. 

28 

96 supply chain and and 3. __The __ location of suppliers, or changes 

The 

Comment 


• DI 11 (p. 28, lines 96 ff) 

o Please clarify the term "significant changes" in the supply chain in a concise manner. 

o Globally operating companies with complex value chains and a huge number of first tier suppliers will simply not be able to report 

on location, changes in relationships and selection and termination of suppliers. 

o Due to competitive reasons, it would not be possible in some specific areas (eg. raw material procurement) to disclose location or 

even name of suppliers. 

o The location of suppliers should only be relevant if it relates directly to sustainability issues (e.g. non-compliance with ESG 

standards of a supplier). 

28 

96-97 __3. The location of suppliers, or changes in relationships with supplie... 


Mediating 

Institution 

Mediating 

Institution 

Europe 

Asia 

Consultant 

Consultant 

Assurance 

Provider 

Business Latin america Reporter 


Business 

Northern 

America 

Reporter 



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termination 

Comment 


DI 11 / 3 – consider deletion – too detailed for a profile disclosure and repetition of the intent within G4.5 to G4.14, HR2 and HR11. 

28 

96-97 __The location of suppliers, or changes in relationships with suppliers,... 

The location of suppliers, or changes in relationships with suppliers, including selection and 

termination 

Comment 


Disclosure DI 11 point 3 asks for the location of suppliers - this is a repeat of question DI 12 point 2C - remove the duplication. As a 

multi-disciplinary company we deal with and manage thousands of suppliers. We do not feel that it is important or would add value 

to know where our suppliers are located. Changes in major suppliers might relevant in to report – especially if you changed supplier 

to improve your sustainability approach. Reconsider the scope and detail of this question. 

28 



termination 

Comment 




28 



termination 

Comment 


This should only be relevant if it relates to sustainability issues (e.g. non-compliance of a supplier with ESG standards) 

28 



termination 

Comment 





Business 

Northern 

America 

Reporter 


Business 

Northern 

America 

Reporter 



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28 



termination 

Replace 


The location of suppliers, FORMS OF COVERING SOCIAL AND ECONOMIC INCLUSION VIA THE SUPPLY CHAIN, or changes in 

relationships with suppliers, including selection and termination 

Civil Society 

Organization 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

RATIONALE: 

Social and Economic inclusion via the supply chain (including organizations that employs people with disabilities) is a way of 

extending organizations commitment to responsible business practices to their value chains. Organizations do so not only because 

of the inherent social risks and the governance challenges the supply chain poses, but also because of the many rewards it can 

deliver. There is increasing legislation favoring goods and services providers that comply with employment regulations for people 

with disabilities, or foster special measures addressed to people with disabilities, in public procurement. 

By reporting the different Forms of Social and Economic Inclusion via the supply chain (including those related to social businesses 

that employ people with disabilities) facilitates knowing the social impact of the organization in terms of helping to the social 

inclusion of vulnerable groups (such as people with disabilities). It could also very be useful for example to demonstrate compliance 

of a particular legislation and as means of benchmarking in social and economic inclusion performance. 

28 



termination 

Comment 


This kind of information might be confidential, e.g. reasons for termination of cooperation, data about strategic suppliers, etc. There 

are general concerns about competitive relevant information in this framework. 

28 



termination 

Comment 


Please clarify the term "significant changes" in the supply chain in a concise manner. 



Globally operating companies with complex value chains and a huge number of first tier suppliers will simply not be able to report 



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on location, changes in relationships and selection and termination of suppliers. 

Due to competitive reasons, it would not be possible in some specific areas (eg. raw material procurement) to disclose location or 

even name of suppliers. 

The location of suppliers should only be relevant if it relates directly to sustainability issues (e.g. non-compliance with ESG standards 

of a supplier). 

28 



termination 

Comment 




28 



termination 

Comment 


Don't believe this is realistic - should be kept "high level" eg strategic approach to supply chain e.g. local v. centralised sourcing 

28 



termination 

Comment 


Exclude this. See previous comment 

28 



termination 

Comment 




Business 

Mediating 

Institution 

Mediating 

Institution 

Business 

Northern 

America 

Europe 

Europe 

Northern 

America 

Reporter 

Consultant 

Assurance 

Provider 

Reporter 

Consultant 

Assurance 

Provider 

Reporter 



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28 



termination 

Comment 




28 



termination 

Comment 


Does this add any value or is it onerous? could this be cut back for now to reduce the reporting burden? 

28 



termination 

Comment 




28 

97 with suppliers, including selection and __termination__ 

termination 

Comment 


Consideration should be given to commercial agreements and breaches of confidentiality. For example, a food manufacturer may 

not want to publicly disclose the location and name of their suppliers for competitive reasons 

28 


termination 

Comment 


Disclosing the requested information on suppliers on an annual basis would be impossible for a global organization whose supply 

base is very larg and complex, to fulfil in a cost effective and meaningful way. It could also present liability issues for the reporter. 

Business 

Mediating 

Institution 

Business 

Northern 

America 

Europe 

Northern 

America 

Reporter 

Reporter 

Consultant 

Report Reader 

GRI Certified 

Training 

Partner 

Reporter 

Business Oceania Consultant 

Assurance 

Provider 




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29 

98 [Disclosure] DI __12 __ Describe the organization’s supply chain. 

12 

Comment 


The number of information required about the organization’s supply chain, especially monetary value and/or value of materials and 

type of suppliers represents a complex activity that may be not feasible for a global company such as Vale. The details should be 

provided in specific indicators, such as EC6 (information by country). Additionally, the concept (weak governance zone) is likely to be 

of difficult application due to the implications of this negative assessment. 

29 

98 [Disclosure] __DI 12 __ Describe the organization’s supply chain. 

DI 12 

Comment 


For mining and other industries operating in more than one location using a vast number of suppliers (many of them small and 

local), it will extremely difficult to aggregate data at a global level on the monetary value and/or volume of materials purchased 

from suppliers broken down by the requested information. 



Publically declaring “weak governance zones” in a report would likely lead to strained, and possible broken relationships with some 

important stakeholders such as local/regional/national governments in developing countries who may not agree with the 

assessment of “weak governance”. 

29 

98 __[Disclosure] DI 12 __ Describe the organization’s supply chain. 

[Disclosure] DI 12 

Comment 


Should add the same disclosure to clients 

29 

98 __[Disclosure] __ DI 12 Describe the organization’s 

[Disclosure] 

Comment 






Report Reader 





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29 

98-110 __DI 12 

Describe the organization’s supply chain. 

[Guidance] A des... 

DI 12 


[Guidance] A description of the supply chain may include but is not limited to: 


1. Total number of suppliers 

2. Total monetary value and/or volume of materials, products and services purchased directly from suppliers, broken down by: 

a. The types of materials, products and services provided by suppliers that are used for the organization’s primary brands, products 

and/or services, as reported under DI 4 

b. Types of suppliers 

c. Location of suppliers by country and/or region. Where it will provide appropriate 

context on relevant risks and impacts, identify the location of suppliers within a country. List those suppliers that are located in 

weak governance zones and Export Processing 

Zones (also called Special Economic Zones or Free Trade Zones) 

Comment 



local), it will be extremely difficult to aggregate data at a global level on the monetary value and/or volume of materials purchased 





29 

98-110 __[Disclosure] DI 12 

Business 

Northern 

America 

Reporter 


[Gu... 




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Comment 


For mining and other industries operating in more than one location using a vast number of suppliers, it will extremely difficult to 

aggregate data at a global level on the monetary value and/or volume of materials purchased from suppliers broken down by the 

requested information. 




29 


Mediating 

Institution 

Europe 

Reporter 

Report Reader 


[Gu... 









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Comment 








29 


Business 

Northern 

America 

Reporter 


[Gu... 













Comment 




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29 




[Gu... 













Comment 










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29 



[Gu... 













Comment 


For mining and other industries operating in more than one location using a vast number of suppliers, it will extremely difficult to 

aggregate data at a global level on the monetary value and/or volume of materials purchased from suppliers broken down by the 

requested information. 

Business 

Northern 

America 

Reporter 




29 




[Gu... 




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Replace 








29 



[Gu... 



Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 









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Comment 








29 


Business 

Northern 

America 

Reporter 


[Gu... 













Comment 





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29 




[Gu... 













Definitions 

See the Glossary for the definitions of supply chain and supplier. 

References 

• OECD Risk Awareness Tool for Multinational Enterprises in Weak Governance Zones (in particular chapters 2, 4 & 7), 2006. 

• Employment and social policy in respect of export processing zones (EPZs), Governing Body, 

286th Session, Geneva, 2003, International Labour Organization 

Comment 




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29 

99 12 Describe the organization’s supply __chain. __ [Guidance] A description of the 

chain. 

Comment 


I would place this disclosure before DI11, first you describe the organization and the supply chain, then the significant changes in the 

organization and supply chain. 

29 

99 DI 12 Describe the organization’s __supply chain. __ [Guidance] A description of the 

supply chain. 

Comment 


this is easier for a production company (f.e. AkzoNobel, Unilever) than a service company 

29 

99 [Disclosure] DI 12 __Describe the organization’s supply chain. __ [Guidance] A description of the 


Comment 


Exclude - see previous comment 

29 

100 description of the supply chain __may __ include but is not limited 

may 

Comment 


may or should? 

29 

100 description of the supply chain __may include __ but is not limited to: 

may include 

Comment 


To us this is not concrete enough - we would write: 

Mediating 

Institution 

Europe 

Consultant 


Mediating 

Institution 

Mediating 

Institution 

Mediating 

Institution 

Europe 

Europe 

Europe 

Reporter 

Consultant 

Assurance 

Provider 

Consultant 

Consultant 

Report Reader 

for academic 

purposes 



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"has at least to include" 

29 

100 description of the supply chain __may include but is not limited to: __ 1. Total number of suppliers 

may include but is not limited to: 

Comment 


Expression is unclear; if this is a "must have" it should say so explicitly. 

29 

100 the organization’s supply chain. [Guidance] __A description of the supply chain may include but is not limited to: __ 1. Total 

number of suppliers 

A description of the supply chain may include but is not limited to: 

Comment 


In this guidance it is very positive that type and location of suppliers I brought forward explicitly. However they are not necessarily 

linked to each other, and companies may chose to report on these aspects, so this link is not explicitly made here. 

It might be appropriate to make the nature of the type of suppliers present per country, more explicit. Suppliers such as exporters 

can be gate keepers towards actors in the primary production or processing, tiers in the supply chain with high risks regarding 

social\environmental\economic performance. 

Therefore it would be considered a positive improvement if making this link between disclosing type of suppliers and their location , 

is made more explicit in the guidance. 

29 




Comment 


I don't agree that this level of disclosure is required here. 

If relevant to the organisation and its stakeholders it should be provided, but not as a standard disclosure as it would appear to be 

presented in this draft for all reporters 

29 




Comment 





Civil Society 

Organization 

Mediating 

Institution 

Business 

Europe 

Europe 

Northern 

America 

Report Reader 

Reporter 

Consultant 

Assurance 

Provider 

Reporter 



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29 




Comment 





29 

100-110 __A description of the supply chain may include but is not limited to: 

... 


Business 

Mediating 

Institution 

Northern 

America 

Europe 

Reporter 

Consultant 

Assurance 

Provider 










Comment 


Much too detailed - This could extend to 1000's of suppliers for a large multinational company with different suppliers in each 

country of operation. Doubt relevance and believe GRI should keep to strategic approach to supply chain management. 

29 

101 but is not limited to: __1. Total number of suppliers __ 2. Total monetary value and/or 


Comment 


DI 12 1 – Consider deletion, number of suppliers is not a particularly insightful indicator and difficult to measure accurately due to 

Business 

Northern 

America 

Reporter 



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supplier subsidiaries, brands, etc. Publically identifying “weak governance zones” could negatively impact relationships with 

governments that may not agree with the assessment of “weak governance.” 

29 

101 is not limited to: 1. __Total number of suppliers __ 2. Total monetary value and/or 

Total number of suppliers 

Comment 


Please specify: the depth of evaluation needs to be defined more precisely; this will have an impact on the amount of data and the 

possibility to evaluate the data. 

29 

101 not limited to: 1. Total __number __ of suppliers 2. Total monetary 

number 

Comment 


- for large decentralized companies with many entities maybe difficult to report on 

29 

101 to: 1. Total number of __suppliers __ 2. Total monetary value and/or 

suppliers 

Comment 


- first tier suppliers? 

- only suppliers or also service providers? 

- active suppliers = were a purchase order was placed in the reporting period vs. all suppliers incl. "sleeping" suppliers 

- Suggestion: number of suppliers/service providers a purchase order was placed within the reporting period 

29 

102 1. Total number of suppliers __2. __ Total monetary value and/or volume 

2. 

Insert 


2.PERCENTAGE OF SUPPLIERS INCLUDED AS “FORMS OF SOCIAL AND ECONOMIC INCLUSION”, BROKEN DOWN BY DIVERSITY 

GROUPS (SUCH AS PEOPLE WITH DISABILITIES). 

RATIONALE: 

By reporting the percentage of suppliers included in the supply chain as “Forms of Social and Economic Inclusion”, broken down by 

diversity type (people with disabilities, ethnic minorities, etc), organizations are accountable of their impact via supply chain on the 

social inclusion of diversity and vulnerable groups (e.g. through the promotion of employment of people with disabilities in the 

value chain, or the application of specific criteria regarding accessibility performance of goods and services provided by the 

suppliers). 


Mediating 

Institution 

Mediating 

Institution 

Civil Society 

Organization 

Europe 

Europe 

Europe 

Consultant 

Consultant 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 



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29 

102-105 __Total monetary value and/or volume of materials, products and services... 

Total monetary value and/or volume of materials, products and services purchased directly from suppliers, broken down by: 


and/or services, as reported under 

Comment 


Such information can have competitive implications. What sustainability purpose is served by such mandated disclosures? 

29 






Comment 


Disclosure of monetary value, supplier type, and material/products could provide a supplier's competitor with enough information 

to outbid them on a future contract. Many companies will not be willing to reveal this information for this reason. 

29 










Comment 


This should only be relevant if it relates to sustainability issues (e.g. non-compliance of a supplier with ESG standards) 

29 

104-105 __The types of materials, products and services provided by suppliers th... 

The types of materials, products and services provided by suppliers that are used for the organization’s primary brands, products 


Comment 


Too detailed to be a requirement. Monetary volume and location (country) should be sufficient. 


Business 

Northern 

America 

Reporter 





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29 

106 DI 4 b. Types of __suppliers __ c. Location of suppliers by 

suppliers 

Comment 


What is meant by type of supplier? 

29 


suppliers 

Comment 


DI 12 #2 b (line 106) – Further guidance could be provided on the nomenclature to describe different types of suppliers. 

29 

106 as reported under DI 4 __b. Types of suppliers __ c. Location of suppliers by 


Comment 


DI 12 / 2b – Consider – “describe geographic location and types of primary suppliers ” 

29 

106 reported under DI 4 b. __Types __ of suppliers c. Location of 

Types 

Comment 


o Types of suppliers: an alignment of GRI’s new definition and the definition e.g. by SAM/DJSI (key/strategic/single source/high 

spend) would be valuable. 

o On the one hand types like manufacturers or wholesalers might be interesting, but on the other hand how to categorize the 

relevance of a supplier to the company? 

29 

106 reported under DI 4 b. __Types __ of suppliers c. Location of 

Types 

Comment 


- What is meant by "type"? 

29 

106 reported under DI 4 b. __Types of suppliers __ c. Location of suppliers by 

Types of suppliers 

Comment 

Mediating 

Institution 

Mediating 

Institution 

Business 

Europe 

Asia 

Northern 

America 

Consultant 

Consultant 

Assurance 

Provider 

Reporter 


Mediating 

Institution 

Europe 

Consultant 




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Please specify: what are the KPIs (e.g. size, service supplier, supplier of goods, etc.)? 

29 



Comment 


Types of suppliers: an alignment of GRI’s new definition and the definition e.g. by SAM/DJSI (key/strategic/single source/high spend) 

would be valuable. 

29 

107 4 b. Types of suppliers __c. __ Location of suppliers by country 

c. 

Insert 


c. FORMS OF SOCIAL AND ECONOMIC INCLUSION, BROKEN DOWN BY DIVERSITY GROUP (SUCH AS PEOPLE WITH DISABILITIES). 

RATIONALE: 

The availability of information regarding the total monetary value and/or volume of materials, products and services purchased 

directly from different types of social and economic inclusion, by diversity group (such as, among others, social businesses that 

employ people with disabilities) facilitates knowing the social and economic impact of the organization linked to responsible 

purchasing practices. 

That information could also be very useful in public procurement that values social business engagement as a benchmarking factor. 


Civil Society 

Organization 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

It is important to remark that public procurement is confronted today with important new challenges including high public deficits 

and the resulting need for the most efficient use of public money. There is a growing demand that public purchasing contributes to 

the achievement of overall societal goals such as fostering innovation, and promoting social inclusion, among others, of people with 

disabilities. 

29 

107 b. Types of suppliers c. __Location __ of suppliers by country and/or 

Location 

Comment 


• DI 12 2c (p. 29) 

o Normally one reports by country and not by specific zones within a country. Where is the value-add in this context which would 

justify the complexity? 

o This is a lot of effort and often does not show real ESG risks, e.g. if many suppliers are traders not located in weak governance 

zones you might still buy products from suppliers located in weak governance zones without knowing! 




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29 

107 b. Types of suppliers c. __Location __ of suppliers by country and/or 

Location 

Comment 


- Locati_ = address of the headoffice of the supplier? A supplier could have entities in many different regions and countries. 

- Suggestion: delete this requirement 

29 

107 b. Types of suppliers c. __Location of suppliers by country and/or region. __ Where it will provide appropriate 

Location of suppliers by country and/or region. 

Comment 



29 

107-110 __Location of suppliers by country and/or region. Where it will provide ... 

Location of suppliers by country and/or region. Where it will provide appropriate 




Comment 


Again as a multi-disciplinary company we deal with and manage thousands of suppliers and will definitely not be able to provide 

information on this aspect or to this level of detail. Point 2 C of the question is also a duplicate of the question in Disclosure DI 11 

point 3. We do not believe that the detail of information requested will add any value to us as an organisation or to our 

shareholders. It seems like we are burdened with collecting information on behalf of the government to help them to make 

informed discussion. This is not industries responsibility. We want to report on issues that make us run a more sustainable business. 

Consideration should be given to take this question out completely 

29 






Comment 


This data is not available in (our) systems yet; maximum depth of evaluation is by country and only for first tier suppliers. 

29 


Mediating 

Institution 

Mediating 

Institution 

Europe 

Europe 

Consultant 

Reporter 

Consultant 

Report Reader 

GRI Certified 

Training 

Partner 






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Comment 


Normally one reports by country and not by specific zones within a country. Where is the value-add in this context which would 

justify the complexity? 

This is a lot of effort and often does not show real ESG risks, e.g. if many suppliers are traders not located in weak governance zones 

you might still buy products from suppliers located in weak governance zones without knowing! 

29 

107-110 __c. Location of suppliers by country and/or region. Where it will provi... 





Comment 


DI 12 / 2c – Consider deletion – too detailed for a profile disclosure but implicit within G4.5 to G4.14, HR2 and HR11. 

29 

109 of suppliers within a country. __List those suppliers that are located in weak governance zones __ and Export Processing Zones 

(also 

List those suppliers that are located in weak governance zones 

Comment 


Disclosure of this content, particularly listing suppliers by name, could provide a competitive advantage to those suppliers' 

competitors. 

29 

109 of suppliers within a country. __List those suppliers that are located in weak governance zones and Export Processing __ Zones 

(also called Special Economic 

List those suppliers that are located in weak governance zones and Export Processing 

Comment 


108 List those suppliers that are located in weak governance zones and Export Processing 109 Zones (also called Special Economic 

Zones or Free Trade Zones) 

Clarification: Not clear what it means to “list those suppliers” – sounds like it means names of actual companies, which reporters 

would be uncomfortable with doing 

Business 

Business 

Mediating 

Institution 

Northern 

America 

Northern 

America 

Oceania 

Reporter 

Reporter 

Reporter 

Consultant 

Assurance 

Provider 

Report Reader 



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Clarification: Significant potential for inconsistency in the ‘weak governance zones’ definition, a stronger definition should be 

provided 

29 

109 those suppliers that are located __in weak governance zones __ and Export Processing Zones (also 

in weak governance zones 

Comment 





29 

113 of supply chain and supplier. __References __ • OECD Risk Awareness Tool 

References 

Comment 


Add: SA8000 Standard 

Business 

Mediating 

Institution 

Northern 

America 

Latin america 

Reporter 

Consultant 

Rationale: Because it is based on conventions of the ILO, UN and national laws 

30 

128 in the value chain. supplier __satisfaction __ surveys, 

satisfaction 

Comment 


This can also include feedback from suppliers training on sustaianability. 

30 

128 topics) in the value chain. __supplier satisfaction surveys,__ 

supplier satisfaction surveys, 

Comment 


As Suppliers are part of the stakeholders and survey is already mentioned in the same paragraph there is no need for this specificity 

(the concept is already implicit) 

30 



Comment 


Organizations should provide channels by which people with disabilities, like any other user/consumer, can exercise their right to 

freedom of expression, working to ensure that barriers are removed (not only to access information but also to be able to provide 


Information 

Users 

Civil Society 

Organization 

Europe 

Europe 

Report Reader 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 



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opinions or exercise a vote, among others) or, just as importantly, working to ensure that new barriers are not created as 

technology infrastructures advance. Lack of access to telecommunications and technology is understood as discrimination by people 

with disabilities and is perceived as a "digital divide". 

30 



Comment 


Please specify: what ist meant by this? should we ask our suppliers how satisfied they are with us or should we ask our internal 

customers, how satisfied they are with suppliers? 

31 

131 __broken down by __ stakeholder group, DEFINING REPORT CONTENT 

broken down by 

Comment 


This will be difficult to measure in and says nothing about quality and outcome. 

31 



Comment 


This will be difficult to measure in a reporting organization and says nothing about quality and outcome. 

31 



Replace 



31 

131 broken __down __ by stakeholder group, DEFINING REPORT 

down 

Comment 




reports 


Business 

Business 

Northern 

America 

Northern 

America 

Reporter 

Reporter 





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31 

131 broken __down __ by stakeholder group, DEFINING REPORT 

down 

Comment 


• DI 23 (p. 31, line 131) 

o What is meant with "broken down by stakeholder group"? If organizations are expected to report a quantitative KPI, this would 

cause a huge effort with no real improvement in the field of sustainability. 

31 

131 broken down __by __ stakeholder group, DEFINING REPORT CONTENT 

by 

Comment 



31 

131-132 __broken down by stakeholder group, __ DEFINING REPORT CONTENT AND BOUNDARIES 

broken down by stakeholder group, 

Comment 



31 



Comment 



31 



Comment 




Business 

Business 

Mediating 

Institution 

Northern 

America 

Northern 

America 

Europe 

Reporter 

Reporter 

Reporter 

Report Reader 




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31 



Comment 


Questions: 

What is meant with "broken down by stakeholder group"? 

If organizations are expected to report a quantitative KPI, this would cause a huge effort without a measurable improvement in the 

field of sustainability. 


31 



Comment 



31 



Comment 



31 



Comment 






31 



Comment 


What is meant with "broken down by stakeholder group"? 




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If organizations are expected to report a quantitative KPI, this would cause a huge effort with no real improvement in the field of 

sustainability. 

31 



Comment 



31 



Comment 


This will be difficult to measure in a multi-site, complex reporting organization and says nothing about quality and outcome of 

engagement. 

31 



Comment 



31 

131-132 broken down __by stakeholder group, __ DEFINING REPORT CONTENT AND BOUNDARIES 

by stakeholder group, 

Comment 


May be easier to breake it down by topic. 


Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 


America 



For example: Schiphol: noise disturbance is relevant for government bodies, municipalities, airlines, employees. 

31 

132 broken down by stakeholder __group, __ DEFINING REPORT CONTENT AND BOUNDARIES 

group, 

Comment 


Vale suggests that the focus of the report should be the issue itself and not the stakeholder group that raised the issue. 

31 



Business 

Northern 

America 

Reporter 



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group, 

Comment 


edit to read: "...broken down by stakeholder group type," Many stakeholder groups are willing to provide candid input only because 

they believe that it will be held in confidence. Adding the word "type" would allow responders to protect their relationships with 

stakeholder groups who might not want their criticism of the company made public. 

45 

581 actions related to the supply __chain, __ explain practices for: • Supplier 

chain, 

Comment 


Lines 581 – 593 –The supply chain disclosures on management approach are general in nature rather than disclosures that would be 

repeated for each aspect, and hence we recommend that these become numbered items and are moved after DI11 and DI12. 

The additional disclosure items for each category (e.g. Labor & Decent Work) and aspect (e.g. employment) should be numbered for 

ease of auditing and assurance purposes for instance, line 810 under the aspect Employment. 

Mediating 

Institution 

Asia 

Consultant 

Assurance 

Provider 

The employment disclosures could be broken down by direct employment and indirect employment to provide greater clarity 

regarding the supply chain employment disclosures compared to direct employment disclosures 

45 

581 additional information on due diligence. __For __ specific actions related to the 

For 

Comment 


Lines 581 – 593 – The supply chain disclosures on management approach listed on lines 581 – 593 can be moved to the standard 

disclosure section. The reason for this is that these disclosures on management approach are general in nature and would not be 

repeated for each material aspect, furthermore they closely relate to DI11 & DL12. 

45 

581 additional information on due diligence. __For __ specific actions related to the 

For 

Comment 


- If explained in detail, this will become very extensive - if explained on high level only it will probably be too generic and not 

comparable to other companies. 

45 

581-593 __For specific actions related to the supply chain, explain practices fo... 

For specific actions related to the supply chain, explain practices for: 

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Institution 

Asia 

Europe 

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• Supplier selection; list the economic, environmental and social criteria used when selecting new suppliers; and describe how the 

use of these criteria is encouraged within the organization 

• Supplier management; explain how expectations are established and defined in contracts with 

suppliers to promote improvement in economic, environmental and social performance 

(including targets and objectives); how suppliers are incentivized and rewarded for economic, 

environmental and social performance; and feedback and dialogue mechanisms for suppliers 

• Product and service design; identify changes, and describe their outcomes and progress 

• Certifying and auditing suppliers; list the type, system, scope, frequency and current status of 

certification and audit 

• Supplier termination; describe systems in place to assess the potential economic, environmental and social impacts of terminating 

a relationship with a supplier, and strategy to mitigate the 

impacts 

Comment 


see above 

45 

582-583 __Supplier selection; list the economic, environmental and social criter... 


of these criteria is encouraged within the organization 

Comment 


Our experience is that companies often operate with risk assessment methodologies, classifying suppliers, and give input to the 

monitoring of these suppliers on social\environmental\economic aspects. The methodology behind these overarching risk 

assessments in definitely not always disclosed. Later on in the guidelines the companies are asked to make explicit their suppliers 

that have a ‘actual or potential adverse impact’ on the environment, labour practices, human rights and society-related 

performance. If an appropriate risk classification methodology is implemented it should make sure these cases are identified; 

however inappropriate classification, can hinder this. Stakeholders should be able to give input on how appropriate the 

classifications system of high-medium-low risk suppliers, both existing and new, is in their perspectives. Disclosure of this 

overarching framework is needed. This seems an appropriate place to include this. 

45 

582-583 __Supplier selection; list the economic, environmental and social criter... 


of these criteria is encouraged within the organization 

Comment 


More complete Guidance about disability issues mainstreamed in the GRI G4 Supply Chain DMA and indicators should be 

particularly interesting as references of criteria used when selecting new suppliers. 

Civil Society 

Organization 

Civil Society 

Organization 

Europe 

Europe 

Report Reader 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 



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45 

584 encouraged within the organization • __Supplier management; explain how expectations are established and defined in 

contracts with __ suppliers to promote improvement in 

Supplier management; explain how expectations are established and defined in contracts with 

Comment 


584 Supplier management; explain how expectations are established and defined in contracts with 

Suggested Additions: Going beyond “how expectations are established”, how are suppliers supported to understand and implement 

the standards? 

45 

584-587 __Supplier management; explain how expectations are established and defi... 

Supplier management; explain how expectations are established and defined in contracts with 

suppliers to promote improvement in economic, environmental and social performance 

(including targets and objectives); how suppliers are incentivized and rewarded for economic, 

environmental and social performance; and feedback and dialogue mechanisms for suppliers 

Comment 


According to ISO 26000 we would add "how suppliers are supported to improve their economic, environmental and social 

performances"(see ISO 26000, p. 9 p. 42 etc.) 

45 

588 dialogue mechanisms for suppliers • __Product and service design; __ identify changes, and describe their 

Product and service design; 

Comment 


The term “product and service design” should be clarified in a concise manner. 

45 

588 for suppliers • Product and __service __ design; identify changes, and describe 

service 

Comment 


• Supply Chain Disclosure (p. 45, line 588) 

o The term “product and service design” should be clarified in a concise manner. 

45 

589 their outcomes and progress • __Certifying and auditing suppliers; __ list the type, system, scope, 

Certifying and auditing suppliers; 

Comment 


589 Certifying and auditing suppliers; list the type, system, scope, frequency and current status of certification and audit 

Mediating 

Institution 

Mediating 

Institution 

Oceania 

Europe 

Reporter 

Consultant 

Assurance 

Provider 

Report Reader 

Consultant 

Report Reader 

for academic 

purposes 



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Report Reader 



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Clarification required on what is meant by ‘current status of certification status of certification and audit’ – does this mean status on 

# of audits completed? Or does it mean status on # of non-compliances found through audit e.g. action, in progress, closed? 

Suggested Additions: should also be a requirement to include: 

o How audit methodologies are inclusive of vulnerable groups – women, migrant workers, subcontracted workers 

o Types of issues found through audit – systemic v one off – how are systemic issues responded to? 

o Explanation of how company is managing auditor ethics and performance 

48 

638 and policy agendas. • Procurement __Practices __ [Disclosure] Report policies and practices 

Practices 

Comment 


These topics could be addressed in each indicator, where material. 

48 

638 protocols, and policy agendas. • __Procurement Practices __ [Disclosure] Report policies and practices 

Procurement Practices 

Comment 


Why is this a DMA and not an indicator? Unclear what is meant by “Report policies and practices used to promote economic 

inclusion when selecting suppliers.” 

48 



Comment 


Why is this a DMA and not an indicator? 

48 

638 protocols, and policy agendas. • __Procurement __ Practices [Disclosure] Report policies and 

Procurement 

Comment 


638 Procurement Policies 

Suggested Addition: Report how procurement teams incentivised on financial and non-financial performance e.g. respect of planned 

lead times 

48 

638-641 __Procurement Practices 


Report policies and practices use... 



Business 

Business 

Mediating 

Institution 

Northern 

America 

Northern 

America 

Oceania 

Reporter 

Reporter 

Reporter 

Consultant 

Assurance 

Provider 

Report Reader 




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Report policies and practices used to select locally-owned suppliers, either organization-wide or for specific locations. 

Comment 




48 







Report policies and practices used to promote economic inclusion when selecting suppliers. 


Report how relationships with suppliers are maintained to enable improvement in economic, 

Comment 




48 








Business 

Northern 

America 

Reporter 


environmental and social performance. 

Comment 




48 



Mediating 

Institution 

Europe 

Reporter 

Report Reader 



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Comment 




48 











Comment 




48 








Business 

Northern 

America 

Reporter 





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Comment 




48 











Comment 




48 










Replace 




48 






Gold Mining 

Company that 

reports in 



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accordance 

with the GRI 

Guideline 



Comment 




48 

639 policy agendas. • Procurement Practices __[Disclosure] __ Report policies and practices used 


Comment 




48 

640 agendas. • Procurement Practices [Disclosure] __Report policies and practices __ used to select locally-owned suppliers, 

Report policies and practices 

Comment 


European regulation does not allow to prefer local suppliers (unfair competition). 

48 

640 and practices used to select __locally-owned __ suppliers, either organization-wide or for 

locally-owned 

Comment 


Please specify: what is exactly meant? Subsidiaries? 

48 

640 and practices used to select __locally-owned __ suppliers, either organization-wide or for 

locally-owned 

Comment 


This is very relative. What is understood to be a locally-owned supplier? 




Mediating 

Institution 

Europe 

Reporter 

Consultant 

Assurance 

Provider 

The issue surely is not one of ownership but of proximity. I would suggest dropping owned, and just refer to local suppliers. 



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48 

640-642 __Report policies and practices used to select locally-owned suppliers, ... 



Comment 


We do not believe that "spending on locally-owned suppliers" is a good indicator for more or less economic sustainability in the 

supply chain. In addition, we find it difficult to define "locally-owned suppliers" and would not have this information in our data 

systems. 

48 

640-644 __Report policies and practices used to select locally-owned suppliers, ... 







Comment 


Why is this a DMA and not an indicator? Unclear what is meant by “Report policies and practices used to promote **economic** 


48 

642 organization-wide or for specific locations. __Report policies and practices used to promote economic inclusion when selecting 

suppliers. __ Report how relationships with suppliers 


Replace 


Report policies and practices used to promote SOCIAL AND economic inclusion when selecting suppliers, INDICATING THE 

REFERENCE TO VULNERABLE GROUPS (SUCH AS PEOPLE WITH DISABILITIES) 

Civil Society 

Organization 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

RATIONALE: 

Making reference both to social and economic inclusion remarks the importance of both concepts as relevant components of 

inclusion. 

48 

642 policies and practices used to __promote economic inclusion __ when selecting suppliers. Report how 

promote economic inclusion 

Comment 


Unclear what is meant by “Report policies and practices used to promote economic inclusion when selecting suppliers.” 

Business 

Northern 

America 

Reporter 



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48 

642 used to promote economic inclusion __when __ selecting suppliers. Report how relationships 

when 

Comment 


This type of information is too detailed for larger multinational organizations. This is not applicable to (our) systems yet. 

48 

643-644 __Report how relationships with suppliers are maintained to enable impro... 



Comment 


DMA - These three disclosures (lines 643-8) could be combined into one simpler version 

49 

645-646 __Report actions taken to identify and adjust the organization’s procu... 

Report actions taken to identify and adjust the organization’s procurement practices that affect suppliers’ performance. 

Comment 


Collecting information on ‘report actions taken to identify and adjust…..’ would be a huge amount of work to undertake globally in a 

cost effective way. 

49 

645-648 __Report actions taken to identify and adjust the organization’s procu... 

Report actions taken to identify and adjust the organization’s procurement practices that affect suppliers’ performance. 


Business 

Northern 

America 

Reporter 


Business 

Northern 

America 

Reporter 

Report how dialogue with suppliers is used to identify how procurement practices affect their 

performance. 

Comment 


See above. DMA - These three disclosures (lines 643-8) could be combined into one simpler version 

49 

647 practices that affect suppliers’ performance. __Report how dialogue __ with suppliers is used to 

Report how dialogue 

Comment 


647 Report how dialogue with suppliers is used to identify how procurement practices affect their performance 

Suggested Addition: … and actions taken to adjust the organization’s procurement practices in response 

49 

650 origin or production conditions of __raw materials __ and production inputs purchased. [Guidance] 

Mediating 

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Consultant 

Assurance 

Provider 

Report Reader 




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raw materials 

Comment 


I assume this is just major or direct raw material use and ot all down stream use of resources. 

49 

652 and production inputs purchased. [Guidance] __Forms of economic inclusion may include but are not limited to: __ • Suppliers 

owned by women 

Forms of economic inclusion may include but are not limited to: 

Replace 


Forms of SOCIAL AND Economic inclusion may include but are not limited to: 

RATIONALE: 

Making reference both to social and economic inclusion remarks the importance of both concepts as relevant components of 

inclusion. 

49 

652 inputs purchased. [Guidance] Forms of __economic inclusion __ may include but are not 

economic inclusion 

Comment 


see above 

49 

652-656 __Forms of economic inclusion may include but are not limited to: 

• ... 


Civil Society 

Organization 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 



• Suppliers owned by women 

• Suppliers owned or staffed by members of vulnerable, marginalized or 

underrepresented social groups 

• Small and medium sized suppliers 

Comment 


We do not believe that a categorization and preference of suppliers into such categories is a good indicator for more or less 

economic sustainability in the supply chain. In contrast, we find it rather discriminatory. In addition, we would not have this 

information in our data systems. 

49 

652-656 __Forms of economic inclusion may include but are not limited to: 




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• ... 


• Suppliers owned by women 

• Suppliers owned or staffed by members of vulnerable, marginalized or 


• Small and medium sized suppliers 

Comment 


see above 

49 

654-655 __Suppliers owned or staffed by members of vulnerable, marginalized or 

... 

Suppliers owned or staffed by members of vulnerable, marginalized or 


Replace 


. SUPPLIERS OWNED OR STAFFED BY PEOPLE WITH DISABILITIES. 

. Suppliers owned or staffed by members of OTHER vulnerable OR DIVERSITY GROUPS 

Civil Society 

Organization 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

RATIONALE: 

Reporting specifically about suppliers owned or staffed by people with disabilities is a way of extending organizations commitment 

to people with disabilities as relevant stakeholders to their value chains and as benchmarking in public procurement, if applicable. 

Organizations do so not only because of the inherent social risks and the governance challenges the supply chain poses, but also 

because of the many rewards it can deliver. There is increasing legislation favoring goods and services providers that comply with 

employment regulations for people with disabilities, or foster special measures addressed to people with disabilities, in public 

procurement. 

49 

655 members of vulnerable, marginalized or __underrepresented social groups __ • Small and medium sized 


Comment 


Does this include BBBEE suppliers or not? 

49 

659-662 but are not limited to: __• Lead times 

• Ordering and payment routines 


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Assurance 

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• Purchasing prices 

• Changing or cancelling orders__ 

• Lead times 

• Ordering and payment routines 

• Purchasing prices 

• Changing or cancelling orders 

Comment 


What is relevance of this - is it ever likely to be material? 

53 

674 ASPECT: PROCUREMENT PRACTICES CORE EC6 __Spending on locally-owned suppliers __ broken down by other forms 

Spending on locally-owned suppliers 

Comment 


It is unlikely that organizations will have this information on an aggregated basis at the global level. 

53 

674 ASPECT: PROCUREMENT PRACTICES CORE EC6 __Spending on locally-owned suppliers broken down by other forms of 

economic inclusion, __ at significant locations of operation 

Spending on locally-owned suppliers broken down by other forms of economic inclusion, 

Comment 


It is unlikely that multi-site, global organizations will have this information on an aggregated basis at the global level. 

53 

674 ASPECT: PROCUREMENT PRACTICES CORE __EC6 __ Spending on locally-owned suppliers broken 

EC6 

Comment 



53 

674 ASPECT: PROCUREMENT PRACTICES __CORE EC6 Spending on locally-owned suppliers broken down __ by other forms of 

economic 

CORE EC6 Spending on locally-owned suppliers broken down 

Comment 



53 

674 ASPECT: PROCUREMENT PRACTICES __CORE EC6 __ Spending on locally-owned suppliers broken 

CORE EC6 

Business 

Business 

Northern 

America 

Northern 

America 

Reporter 

Reporter 






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Comment 


What is a locally-owned supplier? Could this be also a local subsidiary of an international corporation? This is a much to detailed 

indicator. It is not possible for bigger organizations / corporations to collect these data. Our company counts nearly 10.000 suppliers 

worldwide! 

53 

674 PRACTICES CORE EC6 Spending on __locally-owned __ suppliers broken down by other 

locally-owned 

Comment 


define locally owned 

53 


locally-owned 

Comment 


Please specify: what is exactly meant? Subsidiaries? 

53 


locally-owned 

Comment 


As explained in line 640drop owned and just refer to local suppliers 

53 


locally-owned 

Comment 


- locally owned at which level: factory, company, holding? 

- might be challenging to track/update in case of large supplier base. 

53 

674 PROCUREMENT PRACTICES CORE EC6 Spending __on locally-owned suppliers __ broken down by other forms 

on locally-owned suppliers 

Comment 


see former comment: 

we are not allowed to prefer local parties by European laws and regulation (fair competition) 

Mediating 

Institution 

Europe 

Consultant 


Mediating 

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Mediating 

Institution 

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53 

674 down by other forms of __economic __ inclusion, at significant locations of 

economic 

Comment 


This needs to be defined. 

53 

674-675 __CORE EC6 Spending on locally-owned suppliers broken down by other form... 

CORE EC6 Spending on locally-owned suppliers broken down by other forms of economic inclusion, at significant locations of 

operation 

Comment 



53 



operation 

Comment 


We do not believe that "spending on locally-owned suppliers" is a good indicator for more or less economic sustainability in the 

supply chain. In addition, we find it difficult to define "locally-owned suppliers" and would not have this information in our data 

systems. 

53 



operation 

Comment 



53 



operation 

Replace 



53 



Mediating 

Institution 

Europe 

Reporter 

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operation 

Comment 



53 

674-675 __Spending on locally-owned suppliers broken down by other forms of econ... 

Spending on locally-owned suppliers broken down by other forms of economic inclusion, at significant locations of operation 

Comment 



53 



Comment 



53 



Replace 


Spending on locally-owned suppliers broken down by forms of SOCIAL AND economic inclusion, at significant locations of operation. 

RATIONALE: 

Making reference to social and economic inclusion remarks the importance of both concepts as relevant forms/components of 

inclusion. 

53 



Comment 



53 



Comment 

Business 

Business 

Civil Society 

Organization 

Northern 

America 

Northern 

America 

Europe 

Reporter 

Reporter 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 


Business 

Northern 

America 

Reporter 



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53 



Comment 



53 

675 other forms of economic inclusion, __at significant locations of operation __ [Standard Disclosure] Report the total 

at significant locations of operation 

Comment 


It is very difficult to determine and identify all or suppliers, let alone know where they are located. Significant location should be 

removed from this statement. It does not add value. 

53 

677 monetary value of spending on __locally-owned __ suppliers at significant locations of 

locally-owned 

Comment 


local suppliers 

53 

677 on locally-owned suppliers at significant __locations __ of operation. Provide information on 

locations 

Comment 



53 

678 information on how locally-owned suppliers __and significant locations __ of operations were defined. Report 

and significant locations 

Comment 




53 

678 operation. Provide information on how __locally-owned suppliers __ and significant locations of operations 

locally-owned suppliers 


Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 


Mediating 

Institution 

Europe 

Reporter 

Consultant 

Assurance 

Provider 



Mediating 

Institution 

Europe 

Reporter 

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Comment 


local suppliers 

53 

679 significant locations of operations were __defined. __ Report the percentage of total 

defined. 

Comment 


The absolute figures seems to be not relevant as the relative one. Suggestion is to exclude this first requirement. 

53 


locally-owned 

Comment 


local 

53 

680-681 spending on locally-owned suppliers at __significant 

locations __ of operation. Report the percentage 

significant 

locations 

Comment 



53 

680-681 spending on locally-owned suppliers at __significant 

locations of operation. __ Report the percentage of total 

significant 

locations of operation. 

Comment 




53 


locally-owned 

Comment 


local 

Assurance 

Provider 


Mediating 

Institution 

Europe 

Reporter 

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Assurance 

Provider 



Mediating 

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53 

682-683 __Report the percentage of total monetary value of spending on locally-o... 

Report the percentage of total monetary value of spending on locally-owned suppliers at significant 

locations of operation broken down by other forms of economic inclusion, if applicable. 

Replace 


Report the percentage of total monetary value of spending on locally-owned suppliers at significant locations of operation broken 

down by other forms of SOCIAL AND economic inclusion, AND BROKEN DOWN BY DIVERSITY GROUPS. 

RATIONALE: 

Making reference to social and economic inclusion remarks the importance of both concepts as relevant components of inclusion. 

Civil Society 

Organization 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

It seems advisable to provide a general definition of economic and social inclusion at glossary level if used in different parts of the 

GRI G4 exposure draft. The definition should refer/ include the most usual types of suppliers that could be included as “Forms of 

Social and Economic Inclusion” (such as suppliers owned or staffed by people with disabilities, among other diversity groups). 

53 

682-683 spending on locally-owned suppliers at __significant locations __ of operation broken down by 

significant locations 

Comment 



53 

682-683 spending on locally-owned suppliers at __significant locations of operation __ broken down by other forms 

significant locations of operation 

Comment 




53 

682-684 __Report the percentage of total monetary value of spending on locally-o... 

Report the percentage of total monetary value of spending on locally-owned suppliers at significant 

locations of operation broken down by other forms of economic inclusion, if applicable. Provide the 

definition used for ‘other forms of economic inclusion’. 

Comment 


This statement can be combined with statement in line 680 and 681. Duplication. 

53 

684 for ‘other forms of economic __inclusion’. __ CORE G4 1 Spending on 







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inclusion’. 

Comment 


Please definr "economic inclusion". 

53 

685 Spending on suppliers with which __long-term __ agreements exist [Standard Disclosure] Report 

long-term 

Comment 


define long term 

53 

685 Spending on suppliers with which __long-term __ agreements exist [Standard Disclosure] Report 

long-term 

Comment 


"long-term" needs to be defined, although the definition will vary significantly by industry. Suggest removing this disclosure and 

moving it to the sector supplements. 

53 

685 ‘other forms of economic inclusion’. __CORE G4 1 Spending on suppliers with which long-term agreements exist __ [Standard 

Disclosure] Report the percentage 

CORE G4 1 Spending on suppliers with which long-term agreements exist 

Comment 


We do not believe that "spending on suppliers with which long-term agreements exist" is a good indicator for more or less economic 

sustainability in the supply chain. We also find it difficult to define "long-term agreements". 

53 

685 ‘other forms of economic inclusion’. __CORE G4 1 __ Spending on suppliers with which 

CORE G4 1 

Comment 


This is a much to detailed indicator. It is not possible for bigger organizations / corporations to collect these data. Our company 

counts nearly 10.000 suppliers worldwide! 

53 

685-693 __CORE G4 1 Spending on suppliers with which long-term agreements exist ... 


[Standard Disclosure] 

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Report the percentage of total supplier expenditure spent on suppliers with which long-term 

agreements exist. 

CORE G4 2 Percentage of suppliers with which orders were placed for the first time during the 

reporting period 


Report the percentage of total suppliers with which orders were placed for the first time during the reporting period. 

Comment 


Do not understand whow this is material from a sustainability prespective. It goes way beyond reasonable reporting expectations 

53 

687 spent on suppliers with which __long-term __ agreements exist. CORE G4 2 

long-term 

Comment 


What do you mean by "long-term"? Your definition on p. 113 is too vague - and why don´t you write the definition into the glossary 

on terms? 

53 

687-688 __Report the percentage of total supplier expenditure spent on suppliers... 



Comment 


Interesting to include disclosure on what indicators result in a ‘preferred supplier’ or long term agreement. Especially to get 

disclosure on what economic, environmental and social performance indicators are part of this selection process 

53 




Comment 


687 Report the percentage of total supplier expenditure spent on suppliers with which long-term agreements exist (a core 

requirement, how does this change things) 

Suggested Addition: report the percentage of supplier expenditure spent on suppliers with which there has been an active 

relationship for [less than 1 year], [1-2 years], [3-5 years], [5-9 years], [10+ years] 

Mediating 

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53 

687-688 spent on suppliers with which __long-term 

agreements exist. __ CORE G4 2 Percentage of 

long-term 


Comment 


What is a long term agreement. Specify the time frame eg. one year, 3 years 5 year and more? 

53 

688 suppliers with which long-term agreements __exist. __ CORE G4 2 Percentage of 

exist. 

Comment 


This information does not imply that long-term agreements necessarily means same sustainability agenda. 

53 

689 agreements exist. CORE G4 2 __Percentage __ of suppliers with which orders 

Percentage 

Comment 


percentage of new suppliers comared to total suppliers? or active suppliers? 

53 

689 with which long-term agreements exist. __CORE G4 2 __ Percentage of suppliers with which 

CORE G4 2 

Comment 




53 


CORE G4 2 

Comment 


Could be grouped with G4.1. Moreover, justify the relevance of this type of information, mainly because it is a core indicator 

53 

689 with which long-term agreements exist. __CORE __ G4 2 Percentage of suppliers 

CORE 

Comment 



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What is the idea behind this indicator? What does this say about an organization? 

53 

689-690 __CORE G4 2 Percentage of suppliers with which orders were placed for th... 

CORE G4 2 Percentage of suppliers with which orders were placed for the first time during the reporting period 

Comment 


It would be useful to provide the sustainability relevance of such indicators so that the organization can justify the time and effort to 

collate such data 

53 



Comment 


We do not believe that "percentage of suppliers with which orders were placed for the first time" is a good indicator for more or 

less economic sustainability in the supply chain. 

53 

690 first time during the reporting __period __ [Standard Disclosure] Report the percentage 

period 

Comment 


This information does not seem material, especilly because the exchange may be a result of commercial reasons. 

53 

692 Report the percentage of total __suppliers __ with which orders were placed 

suppliers 

Comment 


"percentage of suppliers" seems less likely to be indicative of a company's risk. Suggest changing to "percentage of total supplier 

expenditure". 

54 

694 3 Time taken to pay __suppliers __ [Standard Disclosure] Report the average 

suppliers 

Comment 


This information does not seem to be material for a global sustainability report. 

54 

694 3 Time taken to pay __suppliers __ [Standard Disclosure] Report the average 

suppliers 




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Comment 


It is unlikely that organizations will have this information on an aggregated basis at the global level. An aggregated average of the 

time taken to pay suppliers is meaningless absent context regarding local factors. 

54 

694 CORE G4 3 Time taken __to __ pay suppliers [Standard Disclosure] Report 

to 

Comment 


What is the idea behind this indicator? What does this say about an organization? 

54 

694 CORE G4 3 __Time taken to pay suppliers __ [Standard Disclosure] Report the average 

Time taken to pay suppliers 

Comment 




54 



Comment 


Too much detailed information 

54 



Comment 


No information to be disclosed externally. 

54 



Comment 




54 


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Comment 


IT systems are not designed in the same way throughout the company. These figures could not be collected in a comparable manner 

through all accounting systems companywide. 

54 



Comment 




54 



Comment 




54 



Comment 


It is unlikely that multi-site, global organizations will have this information on an aggregated basis at the global level. An aggregated 

average of the time taken to pay suppliers is meaningless without context regarding local factors. 

54 

694 CORE __G4 __ 3 Time taken to pay 

G4 

Comment 


n aggregated average of the time taken to pay suppliers is meaningless absent context regarding local factors. 

54 


G4 

Comment 


• CORE GA 3 (p. 54, line 698 f) 

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o IT systems are not designed in the same way through a whole company. Figures could not be collected through all Accounting 

systems. 

54 

694 __CORE G4 3 Time taken to pay suppliers __ [Standard Disclosure] Report the average 

CORE G4 3 Time taken to pay suppliers 

Comment 




54 



Comment 


We do not believe that "percentage of suppliers with which orders were placed for the first time" is a good indicator for more or 

less economic sustainability in the supply chain. 

54 



Comment 




54 



Comment 




54 



Replace 




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54 



Comment 




54 

694 __CORE G4 3 __ Time taken to pay suppliers 

CORE G4 3 

Comment 




54 


CORE G4 3 

Comment 


Rather ADDITIONAL than CORE indicator, since mandatory reporting on this indicator for organization with material supply chains is 

too demanding 

54 


CORE G4 3 

Comment 


evaluate better objectives related this type of information because it depends on what was negotiated with each supplier, volumes, 

delivery, etc. 

54 

694 __CORE __ G4 3 Time taken to 

CORE 

Comment 



54 

696 Report the average number of __days __ taken to pay supplier invoices. 

days 

Comment 



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- Standard payment terms can vary from country to country. Therefore, this indicator might not be comparable 

- suggestion: delete this indicator 

54 

696 suppliers [Standard Disclosure] Report the __average __ number of days taken to 

average 

Comment 


indicator G4 3 asks for two disclosure points on line 696 and 697 

54 

697 taken to pay supplier invoices. __Report the percentage of total payments to suppliers that were made late. __ ADD G4 4 

Percentage of 

Report the percentage of total payments to suppliers that were made late. 

Comment 


For a multi-disciplinary company, this is very difficult as we don't always know the reasons behind the late payment. 

54 

697 to suppliers that were made __late. __ ADD G4 4 Percentage of 

late. 

Comment 


And the reasons for late payment 

54 

697 total payments to suppliers that __were made late. __ ADD G4 4 Percentage of 

were made late. 

Comment 


"late" by which definition? Based on the procuring organization's terms of payment, by the supplier's terms (which are often 

disregarded by contract), or a neutral timing (which I am not aware exists)? 

The setting of very long-term payment times in contracts is often contradicting requirements towards the supplier he has to pay his 

staff timely. It is good to see this aspect is core, but especially in this case it would be good to have additional guidance pointing out 

definition of payment terms should be disclosed (= part of DMA for this aspect). 

54 

698 late. ADD G4 4 Percentage __of __ monetary value of each type 

of 

Comment 


• ADD G4 4 (p. 54) 

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o This is simply not feasible for large organizations. If an organization has thousands of product groups, monetary value is supplierrelated 

and not material-related. And each material group might have different suppliers. Most large companies will not have this 

data available. 

o This indicator might also be problematic from an anti-trust point of view. 

54 

698 suppliers that were made late. __ADD G4 4 __ Percentage of monetary value of 

ADD G4 4 

Comment 


comparability is difficult - "internation recognized standards" is too generic and each company may consider a different scopes 

54 

698-700 __ADD G4 4 Percentage of monetary value of each type of materials, produ... 

ADD G4 4 Percentage of monetary value of each type of materials, products and services 

purchased that have been verified or certified as being in accordance with credible, 

widely-recognized economic, environmental and social standards 

Comment 


We do not believe that this is a good indicator for more or less economic sustainability in the supply chain. A majority of products 

and services cannot be certified yet and it is not a given that a certified product or service is more sustainable. It could be up to a 

company not to certify a product or service (e.g. due to certification costs or doubts in the certification method) while still showing a 

better economic, environmental or social performance. In addition, we would not have this data available to report on it. 

54 

698-700 __Percentage of monetary value of each type of materials, products and s... 

Percentage of monetary value of each type of materials, products and services 



Comment 


It would be useful to provide more guidance/references on the standards that are considered relevant under this indicator. 

54 





Comment 


No information on certificates etc. available in (our) systems yet; systems will have to be adjusted; business case for system change? 







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54 





Comment 


This is simply not feasible for large organizations. If an organization has thousands of product groups, monetary value is supplierrelated 

and not material-related. And each material group might have different suppliers. Most large companies will not have this 

data available. 


This indicator might also be problematic from an anti-trust point of view. 

54 

700 being in accordance with credible, __widely-recognized economic, environmental and social standards __ [Standard Disclosure] 

For each type 


Comment 


give examples of these standards 

54 

701 economic, environmental and social standards __[Standard __ Disclosure] For each type of 

[Standard 

Comment 


It is unlikely that organizations have this information on an aggregated basis at the global level nor does it make sense to employ the 

resources to do so. This requirement is vague with regard to what is a “credible” and “widely-recognized standard”. Many 

companies have thousands of suppliers. One example of these are SMEs including farmers and fishermen who have contracts to 

supply dining facilities. It would be extremely difficult to meet this requirement. 

54 

702 report the percentage of the __monetary value __ that has been verified or 

monetary value 

Comment 


if certified input is reported on monetary value, this might cause a screwed image, as often certified inputs can be higher. 

Suggested that this is reported upon as relative volume. 

54 

702-704 __For each type of material, product or service purchased, report the pe... 

For each type of material, product or service purchased, report the percentage of the monetary value that has been verified or 

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certified as being in accordance with credible, widely-recognized economic, environmental and social standards, broken down by 

standard. 

Comment 






54 




standard. 

Comment 






54 




standard. 

Comment 






54 




standard. 

Comment 


702 For each type of material, product or service purchased, report the percentage of the monetary value that has been verified or 

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standard. 

Clarification needed - what’s the definition of ‘credible, widely-recognized’? There are numerous standards in operation which have 

significant uptake, but are widely criticised for not delivering expected standard e.g. ICTI, SA8000 – what is GRI’s response to this 

tension? 

54 




standard. 

Comment 






54 




standard. 

Comment 




companies have thousands of suppliers. 

54 




standard. 

Comment 


Regarding disability, besides references of international initiatives, such as United Nation Convention on the Rights of People with 

disabilities (2006), it would be advisable to provide references of some legislation and standards that could be considered by 

organizations to support broader accountability and transparence on that particular topic. 

Taking in account that many people with disabilities still face difficulties in their everyday lives associated to the use of different kind 


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promote and 

enhance the 

disability 

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of products and services, there are new market opportunities for products and services that are accessible and designed for all, and 

its verification or certification according to accessibility standards (more common in ICT or Construction sectors) would be also of 

great help to assure their accessibility performance. As stated in the roadmap of the European Accessibility Act (expected to be 

adopted by the end of 2012): “Given the correlation between disability and ageing, and the demographic change in Europe, it is 

expected that over 20% of the EU population would benefit from improvements in accessibility of goods and services”. 

54 




standard. 

Comment 






54 




standard. 

Comment 






54 




standard. 

Comment 








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54 




standard. 

Replace 





supply dining facilities. It would be extremely difficult to meet this requirement 

54 




standard. 

Comment 






54 




standard. 

Comment 








Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 

Business 

Northern 

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Reporter 

There may be an oportunity here for gold companies to link to responsible gold standard. 

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standard. 

Comment 






54 




standard. 

Comment 






54 

704 social standards, broken down by __standard.__ 

standard. 

Comment 


It would be great to make reference to standards or provide a list of standards you refer 

54 

704 social standards, broken down by __standard.__ 

standard. 

Comment 


This information seems to be highly complex and does not seem to be material for a global sustainability report. 

56 

733-739 __Remediation 


Report the availability and accessibility o... 

Remediation 


Report the availability and accessibility of grievance mechanisms and remediation processes, 







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and the involvement of local community/workers’ representatives’ in monitoring their 

effectiveness. 

Report the types of training on the availability and accessibility of grievance mechanisms and remediation processes. 

Comment 


This can lead to a repeated and lengthy disclosure of similar information (e.g. in case management approaches are bundled for 

different topics in one system) 

56 

738 Report the types of training __on __ the availability and accessibility of 

on 

Comment 


", if they pertain to internationally recognized conventions, and to whom the training is offered" 

Information 

Users 

Northern 

America 

Report Reader 

Scope of training and adherence to international conventions provide determinants of effectiveness 

56 

738 training on the availability and __accessibility __ of grievance mechanisms and remediation 

accessibility 

Comment 


The definbition of Accessibility should be included at Glossary level 

People with disabilities should be able to use grievance mechanisms in the same conditions as others. 

56 

738-739 __Report the types of training on the availability and accessibility of ... 


Comment 


To whom does this apply? Employees, Supply Chain or communities. 

64 

744 and actions taken [Standard Disclosure] __Report __ the percentage of new suppliers 

Report 

Comment 


G4 5 asks for three different percentage values to be calculated on lines 744, 751 and 753. As such, there seems to be multiple 

disclosure requirements combined into one indicator, whereas it is best practice to ensure that an indicator only measures a single 

data point. Hence this indicator need to be split up into separate indicators or else the indicator wording needs to be revised, and 

the indicator protocol developed for clarity. 

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disability 

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64 

744 suppliers and other business partners __screened __ for environmental performance, broken down 

screened 

Comment 


This needs to be clarified: screened vs. assessed; also relevant for the other categories 

64 

744-745 suppliers and other business partners __screened for environmental 

performance, __ broken down by the location 

screened for environmental 

performance, 

Comment 


I'm not sure how other service companies do this. In our vision there has to be a balance between people, planet and profit aspects. 

64 

748 and other business partner • __The nature of the issue __ • The location of the 

The nature of the issue 

Comment 


748 Clarification needed - What does ‘nature of the issue’ refer to? 

64 

750 supplier and other business partner) __Report __ issues identified through screening. Report 

Report 

Comment 


750 Report issues identified through screening – talks about reporting on issues) 

Suggested addition: “Break down the following four disclosures by”… supplier self-assessment/independent audit 

64 

750 supplier and other business partner) __Report issues identified through screening. __ Report the percentage of new 

Report issues identified through screening. 

Comment 


These will have business confidentiality implications. Competitors can make use of such disclosures to create vulnerabilities 

64 

753-754 __Report the percentage of new suppliers and other business partners tha... 

Report the percentage of new suppliers and other business partners that were not selected or 

contracted as a result of screening. 

Comment 



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Reporting on environmental screening seems to have a high focus on issues identified and adverse impacts. This should stay in the 

guidelines. But possibly it is good to include room where companies can disclose continues choices made for suppliers to establish 

positive impacts. Environmental screenings can also have a positive incentive in them, not only focusing in not buying or investing in 

pollution, but pro-actively supporting green businesses. 

In general this feedback goes for all assessment and screening indicators also on labour practices, human rights, and society-based 

aspects. 

64 

740 ASPECT: __SCREENING AND ASSESSMENT __ CORE G4 5 Percentage of 

SCREENING AND ASSESSMENT 

Comment 


ENVINONMENTAL SCREEENING AND ASSESSMENT > otherwise all supply chain indicators carry the same name 

64 

740 __ASPECT: SCREENING AND ASSESSMENT __ CORE G4 5 Percentage of 

ASPECT: SCREENING AND ASSESSMENT 

Comment 


The Aspect "Screening and Assessment" is repeatedly requested for each category (environment, social etc.). Since this a minimum 

requirement for reporting “in accordance with” G4 this will lead to uneconomical efforts. This can lead to a repeated and lengthy 

disclosure of similar information (e.g. in case management approaches are bundled for different topics in one system); also relevant 

for the other categories. 

Mediating 

Institution 

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Consultant 


Apart from this, the data in this part of the text is widely ok in case the maximum depth of evaluation should be by country and only 

for first tier suppliers; also relevant for the other categories. 

64 

740 __ASPECT: __ SCREENING AND ASSESSMENT CORE G4 

ASPECT: 

Comment 


FOR ADD EN30 above: Reporting aggregated environmental management costs would not be too burdensome, but trying to disclose 

cost broken down by the categories specified would be impossible because some processes and their associated costs are carried by 

different departments in different regions. This variation in process management is occasionally mandated by local regulatory 

requirements. Cost such as Water treatment are relatively easy to aggregate with some accuracy, but costs to manage air quality 

emissions would be extremely difficult. Additionally, it is unknown what is meant by the environmental protection expenditure of 

“prevention”? 

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64 

741 AND ASSESSMENT CORE G4 5 __Percentage __ of new suppliers and other 

Percentage 

Comment 


Please provide further explanation of the purpose of this indicator. 

64 

741 ASPECT: SCREENING AND ASSESSMENT __CORE G4 5 __ Percentage of new suppliers and 

CORE G4 5 

Comment 


review why are only about NEW suppliers, may IT go against the indicator of long-term contracts. sUGGESTION: % Of suppliers 

should be evaluated (remove term "new") 

64 

741 suppliers and other business partners __screened __ for environmental performance, and actions 

screened 

Comment 



64 

741-742 __CORE G4 5 Percentage of new suppliers and other business partners scre... 

CORE G4 5 Percentage of new suppliers and other business partners screened for environmental performance, and actions taken 

Comment 


We do not believe that screening per se is a helpful tool for more sustainability in the supply chain. We believe that it is first needed 

to identify risks in the supply chain and to screen only those suppliers where it makes sense. The pure quantity of suppliers screened 

does not indicate if the screening was of high quality and useful. In addition, the screening methods themselves are often not very 

effective in evaluating suppliers' performance. 

64 



Comment 


Glossary term/explanation is required for “business partners”. 

It is unlikely that organisations will have this information in an aggregated basis at a global/group level. 

64 








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Comment 


This entire supply chain reporting requirement would be impossible to implement in a cost effective manner for a global operation 

with thousands of suppliers located globally. Reviewing Environmental Impact Assessments to determine which of a company’s 

numerous suppliers could have a “potential” impact is far beyond the economic capability of even the largest companies. Listing 

these supplies by location would be cumbersome and the cost of monitoring and reporting on their performance as indicated would 

be prohibitive. This reporting requirement as written requires a reporting company to report on the sustainability performance of 

all of its suppliers (again, these could number thousands), which should be the responsibility of the supplier, not the reporter. 

One example would be a site which operates in Australia may receive parts from a small to medium- sized manufacturer in Germany 

that may have a contract to make the parts with a factory in Turkey that had an environmental incident which could have a shortterm 

or long-term impact on the environment. The relationship between the site in Australia and the manufacturer in Germany is 

not managed at the global level and neither the site nor the global organization would have enough resources to try to track such an 

incident if it occurred. If there were legal proceedings in Turkey regarding the environmental incident, then the reporting 

organization could incur legal liabilities for public reporting the incident pending the outcome of the legal process. Companies can’t 

publically report what other companies are doing without incurring some legal risk. 

Reporting on the location of the supplier would be extremely time consuming and potentially very expensive. 

64 

741-749 __Percentage of new suppliers and other business partners screened for e... 

Percentage of new suppliers and other business partners screened for environmental 

performance, and actions taken 

Business 

Northern 

America 

Reporter 

GRI 

Consortium 

Member 


Report the percentage of new suppliers and other business partners screened for environmental 

performance, broken down by the location of the supplier and other business partner. 

Break down the following four disclosures by: 

• The location of the supplier and other business partner 

• The nature of the issue 

• The location of the issue (if different to the location of the supplier and other business partner) 

Comment 


Supply chains for multinationals are huge. How does this support the increase in number of companies using GRI guidance? 

64 

742 screened for environmental performance, and __actions __ taken [Standard Disclosure] Report the 

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actions 

Comment 


Actions taken is part of the management disclosure and does not have to be included here. 

64 

756 CORE G4 6 Percentage of __existing suppliers __ and other business partners identified 

existing suppliers 

Comment 


The term “existing suppliers” is not specific enough (e.g. active suppliers or all suppliers?) 

64 

756 address the issues identified. CORE __G4 __ 6 Percentage of existing suppliers 

G4 

Comment 


actions taken is part of the management disclosure 

64 

756 issues identified. CORE G4 6 __Percentage __ of existing suppliers and other 

Percentage 

Comment 


Please provide further explanation of the purpose of this indicator.It would be very costly to collect the data to do that monitoring 

and it seems for us that there is confusion in the report boundary related to the responsability of report between the reporting 

organization and the business partners. 

64 

756 to address the issues identified. __CORE G4 6 __ Percentage of existing suppliers and 

CORE G4 6 

Comment 








Companies can’t publically report what other companies are doing without incurring some legal risk. Reporting on the location of 

the supplier would be extremely time consuming and potentially very expensive. 


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64 


CORE G4 6 

Comment 


difficulty of comparability, because there are different methodologies for environmental impact assessment and depending on the 

depth and quality of the evaluation, the results can be different 

64 

756 to address the issues identified. __CORE __ G4 6 Percentage of existing 

CORE 

Comment 


















64 

756-757 __Percentage of existing suppliers and other business partners identifie... 

Percentage of existing suppliers and other business partners identified as having actual and potential adverse impacts 

Comment 


; the wording ‘ suppliers and other business partners identified as having actual and potential adverse impacts on the environment’. 

The same wording is used later in the document regarding labour practices, human rights, and society-based aspects. This wording 

seems very open tot interpretation; on the one hand it is every supplier, all organisations have some sort of adverse impact, 

especially on the environment. On the other hand it could read like only having to report on high likelihoods or occurrences where 

laws are breached, e.g. systemic pollution. As this is something that could very well not be in line with local legislation, we feel 

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companies will not be inclined to publish this in such detail. 

the wording reminds us of the UNGP on Human rights, and if this is an attempt to streamline the G4 with this framewrok this is very 

positive. 

however for companies, especially the ones starting with reporting, we feel more guidance should be given what is meant here. We 

feel that this is a positive attempt to inspire companies to report on non-conformities and challenges present, something which is 

highly needed in reporting. However we feel the wording will lead to companies being either lost, or taking a convenient definition 

of what a ‘actual or potential adverse impact ‘ is. 

Possibly include disclosure of those instances where non-conformities with codes or standards in place are found, making it more 

explicit for corporations that are already dealing with these mechanisms. 

64 

756-757 other business partners identified as __having actual and potential adverse __ impacts on the environment assessed 

having actual and potential adverse 

Comment 


This must again only be for significant impacts with clear definition of significant 

64 

756-758 __CORE G4 6 Percentage of existing suppliers and other business partners... 

CORE G4 6 Percentage of existing suppliers and other business partners identified as having actual and potential adverse impacts on 

the environment assessed on environmental 


Comment 









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Comment 

















64 


Percentage of existing suppliers and other business partners identified as having actual and potential adverse impacts on the 

environment assessed on environmental 


Comment 


This indicator actually includes two indicators: 

- percentage of suppliers and busines partners identified as ... on the environment 

- percentage of suppliers and busines partners identified as ... on the environment assessed 

Mediating 

Institution 

Europe 

Consultant 

The first one indicated the percentage of risk supliers compared to the total number of suppliers. The percentage cabn be based on 



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number of suppliers or spendings on suppliers. 

Tthe second one indicates the percentage of risk suppliers assessed compared tot the total number of risk suppliers. 

64 




performance, and actions 

Comment 


Again, the sheer size of the supply chain and number of business partners makes this indicator nearly impossible to complete. 

64 





Comment 








64 





Comment 








64 


Business 

Business 

Business 

Business 

Northern 

America 

Northern 

America 

Northern 

America 

Northern 

America 

Reporter 

GRI 

Consortium 

Member 

Reporter 

Reporter 

Reporter 



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Comment 


continued for 760-775:This entire supply chain reporting requirement would be impossible to implement in a cost effective manner 

for a global operation with thousands of suppliers located globally. Reviewing Environmental Impact Assessments to determine 

which of a company’s numerous suppliers could have a “potential” impact is far beyond the economic capability of even the largest 

companies. Listing these supplies by location would be cumbersome and the cost of monitoring and reporting on their performance 

as indicated would be prohibitive. This reporting requirement as written requires a reporting company to report on the 

sustainability performance of all of its suppliers (again, these could number thousands), which should be the responsibility of the 

supplier, not the reporter. 









64 







Comment 









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64 





Business 

Northern 

America 

Reporter 


Comment 


This entire supply chain reporting requirement would be impossible to implement in a cost effective manor for a global operation 

with thousands of suppliers located globally. Reviewing Environmental Impact Assessment to determine which of a company’s 




all of its suppliers (again, which could number thousands), which should be the responsibility of the supplier, not the reporter. 






organization could incur legal liabilities for public reporting the incident pending the outcome of the legal process. Companies just 

can’t publically report what other companies are doing without incurring some legal risk. 

Reporting on the number of contracts issued with clauses related to environmental performance would not be too difficult, and 

reporting on the % of contracts issued with clauses could also be a metric. However, reporting on the location of the supplier would 

be extremely time consuming and potentially very expensive. 



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64 






Replace 

















64 







Comment 


This entire supply chain reporting requirement would be impossible to implement in a cost-effective manner for a global operation 






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One example would be a site which operates in Australia may receive parts from a small-to-medium- sized manufacturer in 

Germany that may have a contract to make the parts with a factory in Turkey that had an environmental incident which could have 

a short-term or long-term impact on the environment. The relationship between the site in Australia and the manufacturer in 

Germany is not managed at the global level and neither the site nor the global organization would have enough resources to try to 

track such an incident if it occurred. If there were legal proceedings in Turkey regarding the environmental incident, then the 

reporting organization could incur legal liabilities for public reporting the incident pending the outcome of the legal process. 

Companies can’t publically report what other companies are doing without incurring some legal risk. 


64 






Comment 









Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 











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64 

757 adverse impacts on the environment __assessed __ on environmental performance, and actions 

assessed 

Comment 


This needs to be defined: what kind of assessments? 

64 

758 environment assessed on environmental performance, __and actions taken __ [Standard Disclosure] 

and actions taken 

Comment 


This is dependent on sphere of influence 

65 

760-762 __Report the number of existing suppliers and other business partners id... 

Report the number of existing suppliers and other business partners identified as having actual and 

potential adverse impacts on the environment, broken down by the location of the supplier and other 

business partner. 

Comment 


See comment above. One example would be a site which operates in Australia may receive parts from a small to medium- sized 

manufacturer in Germany that may have a contract to make the parts with a factory in Turkey that had an environmental incident 

which could have a short-term or long-term impact on the environment. The relationship between the site in Australia and the 

manufacturer in Germany is not managed at the global level and neither the site nor the global organization would have enough 

resources to try to track such an incident if it occurred. If there were legal proceedings in Turkey regarding the environmental 

incident, then the reporting organization could incur legal liabilities for public reporting the incident pending the outcome of the 

legal process. Companies can’t publically report what other companies are doing without incurring some legal risk. 



Business 

Northern 

America 

Reporter 


Is this not another opportunity for Gold Mining compniaes to link to World Gold Council's Responsible Gold Standard? 

65 






Report the percentage of total existing suppliers and other business partners identified as having actual and potential adverse 

impacts 

Comment 



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Difference between "number of suppliers" and "total number " of suppliers not clear 

65 






impacts on the environment, broken down by the location of the supplier and 

other business partner. 

For suppliers and other business partners identified as having actual and potential adverse 

environmental impacts: report the percentage of contracts that included clauses setting expectations on environmental 


Report the percentage of existing suppliers and other business partners identified as having actual and 

potential adverse impacts on the environment that were assessed on environmental performance, 

broken down by the location of the supplier and other business partner. 





Comment 








An example if the difficulty: A site which operates in Australia may receive parts from a small to medium- sized manufacturer in 




Business 

Northern 

America 

Reporter 



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Companies just can’t publically report what other companies are doing without incurring some legal risk. 




65 





Mediating 

Institution 

Europe 

Reporter 

Report Reader 














Comment 



65 








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Comment 






be prohibitive. This reporting requirement as written requires a reporting company to report on the sustainability performance of all 

of its suppliers (again, these could number thousands), which should be the responsibility of the supplier, not the reporter. 









65 





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Comment 

















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Business 

Northern 

America 

Reporter 














Comment 














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organization could incur legal liabilities for public reporting the incident pending the outcome of the legal process. Companies just 

can’t publically report what other companies are doing without incurring some legal risk. 




65 



















Replace 










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Comment 


This entire supply chain reporting requirement would be impossible to implement in a cost-effective manner for a global operation 





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One example would be a site which operates in Australia may receive parts from a small-to-medium- sized manufacturer in 






Companies can’t publically report what other companies are doing without incurring some legal risk. 


65 





Business 

Northern 

America 

Reporter 

GRI 

Consortium 

Member 














Report issues identified through assessment. 



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Report the percentage of contracts with suppliers 

Comment 


Impossible task 

65 

761 as having actual and potential __adverse impacts __ on the environment, broken down 

adverse impacts 

Comment 


Difficult indicator: what do you mean by adverse impact: every company produces CO2 emissions. 


Difference between production companies and service companies. 

May be GRI can give some examples. 

65 

761 impacts on the environment, broken __down __ by the location of the 

down 

Comment 



65 

763-765 __Report the percentage of total existing suppliers and other business p... 




Comment 


Only first tier supplier data; it should be % of order volume; also relevant for the other categories. 

65 

764-765 adverse impacts on the environment, __broken down by the location of the supplier and 

other business partner. __ For suppliers and other business 

broken down by the location of the supplier and 


Comment 



Mediating 

Institution 

Europe 

Reporter 

Consultant 

Report Reader 

GRI Certified 

Training 

Partner 


Mediating 

Institution 

Europe 

Reporter 

Consultant 

Report Reader 

GRI Certified 

Training 

Partner 



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65 

766-768 __For suppliers and other business partners identified as having actual ... 




Comment 


This data is not available in (our) systems; also relevant for the other categories. 

65 

768 setting expectations on environmental performance, __broken down by the location of the supplier and other business __ 

partner. Report the percentage of 

broken down by the location of the supplier and other business 

Comment 



65 

769-771 __Report the percentage of existing suppliers and other business partner... 




Comment 


Only first tier supplier data; it should be % of order volume; also relevant for the other categories. 

65 

771 were assessed on environmental performance, __broken down by the location of the supplier and other business partner. __ 

Break down the following four 


Comment 



65 

772-776 __Break down the following four disclosures by: 

• The location of th... 





Mediating 

Institution 

Europe 

Reporter 

Consultant 

Report Reader 

GRI Certified 

Training 

Partner 


Mediating 

Institution 

Europe 

Reporter 

Consultant 

Report Reader 

GRI Certified 

Training 

Partner 




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• The location of the issue (if different to the location of the supplier and other business partner) Report issues identified through 

assessment. 

Comment 


These will have confidentiality and competion protection implications 

65 

773-775 __The location of the supplier and other business partner 

• The natur... 

The location of the supplier and other business partner 



Comment 


In reality, this indicator could not be reported on. One example would be a site which operates in Australia may receive parts from a 

small to medium- sized manufacturer in Germany that may have a contract to make the parts with a factory in Turkey that had an 

environmental incident which could have a short-term or long-term impact on the environment. The relationship between the site 

in Australia and the manufacturer in Germany is not managed at the global level and neither the site nor the global organization 

would have enough resources to try to track such an incident if it occurred. If there were legal proceedings in Turkey regarding the 

environmental incident, then the reporting organization could incur legal liabilities for public reporting the incident pending the 

outcome of the legal process. Companies can’t publically report what other companies are doing without incurring some legal risk. 

65 

777-779 __Report the percentage of contracts with suppliers and other business p... 

Report the percentage of contracts with suppliers and other business partners identified as having 

actual and potential adverse impacts on the environment where improvements were agreed upon and achieved as a result of 

assessment. 

Comment 



65 

780-782 __Report the percentage of contracts with suppliers and other business p... 

Report the percentage of contracts with suppliers and other business partners identified as having 

actual and potential adverse impacts on the environment that were terminated as a result of 

assessment. 

Comment 



65 

784 address the issues identified. ASPECT: __REMEDIATION __ CORE G4 7 Number of 

Business 

Northern 

America 

Reporter 



Mediating 

Institution 

Europe 

Consultant 



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REMEDIATION 

Comment 


ENVIRONMENTAL REMENDIATION > Otherwise all remediation indicators carry the same name 

65 

784-795 __ASPECT: REMEDIATION 

CORE G4 7 Number of grievances about environment... 

ASPECT: REMEDIATION 

CORE G4 7 Number of grievances about environmental impacts filed, addressed, and resolved 

through formal grievance mechanisms 


Report the total number of grievances about environmental impacts filed through formal organizational grievance mechanisms, 

broken down by the nature and location of the grievance. 

Report which of the following parties filed each grievance: 

• Internal stakeholders 

• External stakeholders, including suppliers 

• Individuals or groups of people identified by: 

o Membership of underrepresented social groups 


o Other indicators of diversity, if applicable 

Comment 


The Aspect "Remediation" is repeatedly requested for each category (environment, social etc.). Since this a minimum requirement 

for reporting “in accordance with” G4 this will lead to uneconomical efforts. This can lead to a repeated and lengthy disclosure of 

similar information (e.g. in case management approaches are bundled for different topics in one system); also relevant for the other 

categories. 

65 

785 CORE G4 7 Number of __grievances __ about environmental impacts filed, addressed, 

grievances 

Comment 


Business 

Northern 

America 

Reporter 



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Please consider this response with all of the proposed new indicators on grievances (environment, human rights, labour practices, 

society). It is widely accepted in the human rights arena that reporting a number of grievances is meaningless. A low number may 

mean that a grievance mechanism is not functioning properly/the community is not aware of it etc. This was covered in extensive 

discussions during the development of the Mining and Metals Sector Supplement and the logic is supported by numerous human 

rights practitioners. 

Another concern with these indicators is protecting the identity of the complainant. If a reporter is identifying the nature, location 

and type of party that filed the grievance (as required in the exposure draft), it is unlikely that anonymity will be maintained. 

65 

785 issues identified. ASPECT: REMEDIATION CORE __G4 __ 7 Number of grievances about 

G4 

Comment 


• G4 7 (p. 65): 

o Why are suppliers not indicated specifically in G4 7, although G4 5 and 6 are related to suppliers specifically? Who are other 

business partners? Please define. 

65 

785 the issues identified. ASPECT: REMEDIATION __CORE G4 7 Number of grievances about environmental impacts filed, 

addressed, and resolved __ through formal grievance mechanisms [Standard 


Comment 









65 

785-786 __CORE G4 7 Number of grievances about environmental impacts filed, addr... 



Comment 


his indicator needs to be defined in more detail. Who files a grievance against whom? The supplier vs. a company? External 

stakeholders (e.g. NGO, local communities) vs. a company`s supply chain? 


Business 

Northern 

America 

Reporter 




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65 




Comment 


). It is widely accepted in the human rights arena that reporting a number of grievances is meaningless. A low number may mean 

that a grievance mechanism is not functioning properly/the community is not aware of it etc. This was covered in extensive 






65 




Replace 









65 




Comment 











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65 

785-786 __Number of grievances about environmental impacts filed, addressed, and... 

Number of grievances about environmental impacts filed, addressed, and resolved 


Comment 







Mediating 

Institution 

Europe 

Reporter 

Report Reader 



65 



through formal grievance 

Comment 








Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 



65 




Business 

Northern 

America 

Reporter 




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Report the total number of grievances about environmental impacts filed through formal organizational grievance mechanisms, 








Comment 









65 

794-795 of people identified by: o __Membership of underrepresented social groups o Other indicators of diversity, if applicable __ 

Of the identified grievances, report 

Membership of underrepresented social groups o Other indicators of diversity, if applicable 

Replace 


. MEMBERSHIP OF DIVERSITY GROUPS, if applicable 

RATIONALE: 

It should be unified along the GRI G4 guidelines the references to under-represented / underrepresented groups, vulnerable groups, 

indicators of diversity (suggested change to diversity groups), marginalized groups and “Economic Inclusion” (suggested change to 

Social and Economic Inclusion) and the definitions included at glossary level (when used in more than one place). 

65 

796 indicators of diversity, if applicable __Of the identified grievances, report how many were:__ 

Of the identified grievances, report how many were: 

Comment 

Civil Society 

Organization 

Mediating 

Institution 

Europe 

Latin america 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

Reporter 

Consultant 

Report Reader 



Page 1437 of 2491


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To Add in EN 3: 

-Report energy efficiency from Organization to expressed in %. 

-Report energy efficiency of: 

a) electricity 

b) water 

c) fuel 

d) others... 

-Report energy efficiency benchmarking for to improvement in after period. 

66 

800-801 __Break down the above disclosure by the nature and location of the grie... 

Break down the above disclosure by the nature and location of the grievance, and the party that filed the grievance. 

Comment 


seems to repeat 789 

66 

809 as the primary reference points. __[Disclosure] __ Report actions taken to determine 


Comment 


This information is impossible to report on in detail for large global organisations. In addition, the reporting requirements here 

should mainly be in the format of indicators, not DMA. 

66 



Comment 




66 



Comment 


Disclosure Supply Chain Lines 809 to 852. 



Mediating 

Institution 

Europe 

Reporter 

Consultant 

Report Reader 

GRI Certified 

Training 

Partner 



Business 

Northern 

America 

Reporter 



Page 1438 of 2491


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66 



Comment 


The supply chain details required are very complex for a global organization such as Vale. Our suggestion is that the report should 

focus on the reporting organization management practices concerning the used mechanisms to verify the practices adopted by its 

suppliers and not the details. 

66 

809-813 __[Disclosure] 

Report actions taken to determine whether work undertake... 


Report actions taken to determine whether work undertaken within the organization’s supply chain takes place within appropriate 

institutional and legal frameworks. 

Report actions taken to address situations where work undertaken within the organization’s 

supply chain does not take place within appropriate institutional and legal frameworks. 

Comment 




66 








Comment 




66 







Business 

Northern 

America 

Reporter 


Business 

Northern 

America 

Reporter 



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Comment 


comment runs through 809-852:This information is impossible to report on in detail for large global organisations. In addition, the 

reporting requirements here should mainly be in the format of indicators, not DMA. 

66 








Comment 


First tier evaluation is terminally possible; second tier or further is not possible and might not become possible in the near future; 

this comment is valid up to line 834 for every requirement concerning the supply chain. 

66 








Comment 


Line 809-852: This information is impossible to report on in detail for large global organisations. In addition, the reporting 

requirements here should mainly be in the format of indicators, not DMA. 

66 













Page 1440 of 2491


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Comment 




66 








Comment 


comment for lines 809-852: This information is impossible to report on in detail for large global organisations. In addition, the 

reporting requirements here should mainly be in the format of indicators, not DMA. 

66 








Replace 




66 








Comment 


Business 

Northern 

America 

Reporter 



Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 



Page 1441 of 2491


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66 








Comment 


Lines 809-852 (difficult to highlight all lines). 



66 

810 primary reference points. [Disclosure] Report __actions __ taken to determine whether work 

actions 

Comment 


the focus of these disclosures is on the supply chain. do not forget the own organization! 

66 

810 the primary reference points. [Disclosure] __Report __ actions taken to determine whether 

Report 

Comment 


The supply chain details required are very complex for a global organization such as Vale. Our suggestion is that the report should 

focus on the reporting organization management practices concerning the used mechanisms to verify the practices adopted by its 

suppliers and not the details. 

66 

810-813 __Report actions taken to determine whether work undertaken within the o... 




supply chain does not take place 

Comment 


These requirements require organizations to assume role of government and at most can be applied to organizations with 


Mediating 

Institution 

Europe 

Consultant 





Page 1442 of 2491


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international supply chains such as WallMart or Apple. For organizations whose supply chain is within the country, should it take on 

what the government should do? Will have serious relationship issues 

66 






Comment 


These additional disclosures versus G3.1 all start with the words “Report actions taken to” which is retrospective, lagging 

information on the final step of the normal management process. Many of these are focused on the supply chain, especially legal 

compliance, in addition to the substantial information requested in the indicators. This type of reporting does not encourage the 

development of an engaging narrative to describe the company’s processes and systems to mitigate impacts and create benefits in 

the supply chain, and also does not look towards future improvements or new commitments by the company on its approach. 

66 






Comment 


DMA – These additional disclosures versus G3.1 all start with the words “Report actions taken to” which is only the final step of the 

management process. Many of these are focused on the supply chain, especially legal compliance, in addition to the substantial 

information requested in the indicators. This type of reporting does not encourage the development of an engaging narrative to 

describe the company’s processes and systems to mitigate impacts and create benefits in the supply chain, and also does not look 

towards future improvements or new commitments by the company on its approach. 

66 

811 supply chain takes place within __appropriate institutional and legal frameworks. __ Report actions taken to address 

appropriate institutional and legal frameworks. 

Comment 


This needs clarification. In addition, the reporting requirements here should mainly be in the format of indicators, not DMA. 

66 

812-813 __Report actions taken to address situations where work undertaken withi... 




Business 

Business 

Civil Society 

Organization 

Northern 

America 

Northern 

America 

Europe 

Reporter 

Reporter 

Report Reader 

Work to 

promote and 

enhance the 



Page 1443 of 2491


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Comment 


References of appropriate “institutional and legal frameworks” for a particular topic could be of great help to implementation and 

disclosure on it. 

disability 

disclosure in 


reports 

Regarding Disability, the United Nation Convention on the Rights of Persons with Disabilities (2006) should be included 

(http://www.un.org/disabilities/default.asp?id=259) 

67 

814 __Report __ actions taken to determine whether 

Report 

Comment 


These requirements require organizations to assume role of government and at most can be applied to organizations with 

international supply chains such as WallMart or Apple. For organizations whose supply chain is within the country, should it take on 

what the government should do? Will have serious relationship issues 

67 

814-826 __Report actions taken to determine whether the working conditions of pe... 

Report actions taken to determine whether the working conditions of persons working for 

suppliers are consistent with international labor standards and/or national labor law. 

Report actions taken to determine whether persons working for suppliers are provided the 

social and labor protection that they are entitled to receive by national labor law. 

Report actions taken to address situations where working conditions in the organization’s 

supply chain were found to not meet international standards and/or national labor law. 

Report actions taken to determine whether persons working for suppliers are adequately 

remunerated. 


supply chain is inadequately remunerated. 

Report actions taken to determine whether suppliers use sub-contractors or intermediaries, and whether there are disguised 

employment relationships where workers are falsely considered to be self-employed or where there is no legally recognized 

employer. 

Comment 




67 






Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 

Business 

Northern 

America 

Reporter 



Page 1444 of 2491


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remunerated. 





employer. 

Report actions taken to address situations of disguised employment relationships where 

workers in the organization’s supply chain are falsely considered to be self-employed or where 

there is no legally recognized employer. 

Report actions taken to determine whether work undertaken within the organization’s supply 

chain is performed at home and whether it is performed subject to a legally-recognized 

contract. 


supply chain performed at home is not performed subject to a legally-recognized contract. 

Comment 


DMA – These additional disclosures versus G3.1 all start with the words “Report actions taken to” which is only the final step of the 

management process. Many of these are focused on the supply chain, especially legal compliance, in addition to the substantial 

information requested in the indicators. This type of reporting does not encourage the development of an engaging narrative to 

describe the company’s processes and systems to mitigate impacts and create benefits in the supply chain, and also does not look 

towards future improvements or new commitments by the company on its approach. 

67 









remunerated. 



Business 

Northern 

America 

Reporter 



Page 1445 of 2491


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employer. 






contract. 



[Guidance] 

Work taking place within an appropriate institutional and legal framework will usually entail a 

recognized employment relationship with an identifiable and legally recognized employer. 

Conditions of work include but are not limited to compensation, working time, rest periods, 

holidays, disciplinary and dismissal practices, maternity protection, the workplace environment, the quality of living 

accommodations where provided, and welfare matters such as safe drinking water, canteens and access to medical services. 

Adequately remunerated work means that wages and compensation for a standard working 

week, excluding overtime, meet legal and industry minimum standards and are sufficient to 

meet the basic needs of workers and their families and provide some discretionary income. 

Actions taken to address situations where work is inadequately remunerated may include but 

Comment 




Additionally, Line 827: The accusatory tone of this disclosure needs addressing. The intent behind it is not clear and it reads as an 

advocacy piece rather than a disclosure item. 

67 









remunerated. 

Mediating 

Institution 

Europe 

Reporter 

Report Reader 



Page 1446 of 2491


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employer. 






contract. 



[Guidance] 










are not limited to: 

• Dialogue with suppliers regarding the relationship of the prices paid to suppliers and the wages paid to workers 

• Changes to the organization’s procurement practices 

• Support for collective bargaining to determine wages 

• Determining the extent that overtime is used, whether it is mandatory, and whether it is compensated at a premium rate 

Comment 




The accusatory tone of line 827 needs addressing. The intent behind it is not clear and it currently reads as an advocacy statement 

rather than a disclosure item. 

67 





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remunerated. 





employer. 






contract. 



[Guidance] 















Replace 



Page 1448 of 2491


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67 









remunerated. 





employer. 






contract. 



[Guidance] 














Page 1449 of 2491


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Comment 




LINES 827-829: The accusatory tone of this disclosure needs addressing. The intent behind it is not clear and it currently reads as an 

advocacy piece rather than a disclosure item. 

67 

824 supply chain is inadequately remunerated. __Report actions __ taken to determine whether suppliers 

Report actions 

Comment 


824 Report actions taken to determine whether suppliers use sub-contractors or intermediaries, and whether there are disguised 

employment relationships where workers are falsely considered to 825 be self-employed or where there is no legally recognized 

employer. 

Suggested Addition: whether suppliers use sub-contractors… or ‘labour agencies’ 

67 

827 is no legally recognized employer. __Report actions taken to address situations of disguised employment relationships where 

__ workers in the organization’s supply 


Comment 


The accusatory tone of this disclosure needs addressing. The intent behind it is not clear and it reads as an advocacy piece rather 

than a disclosure item. 

67 

827 taken to address situations of __disguised employment relationships where __ workers in the organization’s supply 

disguised employment relationships where 

Comment 


The accusatory tone of this disclosure needs addressing. The intent behind it is not clear and it currently reads as an advocacy piece 


67 

827-829 __Report actions taken to address situations of disguised employment rel... 


Mediating 

Institution 

Business 

Oceania 

Northern 

America 

Reporter 

Consultant 

Assurance 

Provider 

Report Reader 

Reporter 





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workers in the organization’s supply chain are falsely considered to be self-employed or where there is no legally recognized 

employer. 

Comment 




67 




employer. 

Comment 




67 




employer. 

Comment 




67 




employer. 

Comment 




67 




employer. 

Business 

Northern 

America 

Reporter 




Gold Mining 

Company that 

reports in 

accordance 



Page 1451 of 2491


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Comment 




67 




employer. 

Comment 




67 




employer. 

Comment 




67 

839 and dismissal practices, maternity protection, __the workplace environment, __ the quality of living accommodations 

the workplace environment, 

Comment 


[..] SUITABILITY AND ACCESSIBILITY OF the workplace environment 

RATIONALE: 

. Accessibility is defined as an integral part of people with disabilities rights in article 9 of the United Nations Convention on the 

Rights of Persons with Disabilities (2006, http://www.un.org/disabilities/default.asp?id=269) 

67 



Comment 


Vague - include workplace "health and safety" 

Business 

Business 

Civil Society 

Organization 

Civil Society 

Organization 

Northern 

America 

Northern 

America 

Europe 

Northern 

America 

with the GRI 

Guideline 

Reporter 

Reporter 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

Report Reader 



Page 1452 of 2491


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67 



Comment 


Too vague - should mention worker safety and health in here as well 

67 



Comment 


We suggest the phrase occupational safety and health should be used here, as it is a more inclusive term. 

67 

846-852 __are not limited to: 

• Dialogue with suppliers regarding the relatio... 






Comment 


Same as above 

68 

861 level, and equal remuneration. • __Screening __ and Assessment • Remediation [Disclosure] 

Screening 

Comment 


The relevance of this disclosure to labour practices is unclear. This information is required by other disclosures and the linkages are 

unclear. 

68 

861 level, and equal remuneration. • __Screening __ and Assessment • Remediation [Disclosure] 

Screening 

Comment 


Please clarify the link between this disclosure and other related disclosures requirements on labour practices. 

Civil Society 

Organization 

Northern 

America 

Report Reader 


Our members 

help 

organisations 

prepare and 

use 


reports 


America 





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68 

861-867 __Screening and Assessment 

• Remediation 


Report the ... 

Screening and Assessment 







Report the types of training on the availability 

Comment 



unclear. 

68 


Mediating 

Institution 

Europe 

Reporter 

Report Reader 










Report the types of training on the availability and accessibility of grievance mechanisms and 

remediation processes. 

Comment 



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unclear. 

68 







Business 

Northern 

America 

Reporter 







Comment 



unclear. 

68 













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Comment 



unclear. 

68 














Comment 



unclear. 

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Replace 



unclear. 

68 







Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 








Comment 



unclear. 

68 


Business 

Northern 

America 

Reporter 





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Comment 



unclear. 

68 

861-868 __• Screening and Assessment 




Report ... 

• Screening and Assessment 








Comment 



unclear. 

68 

864 and Assessment • Remediation [Disclosure] __Report the availability and accessibility of grievance mechanisms and 

Civil Society 

Organization 

Europe 

Report Reader 

Work to 



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remediation processes, __ and the involvement of local 


Comment 


Organizations should provide channels by which people with disabilities, like any other user/consumer, can exercise their right to 

freedom of expression, working to ensure that barriers are removed (not only to access information but also to be able to provide 

opinions or exercise a vote, among others) or, just as importantly, working to ensure that new barriers are not created as 

technology infrastructures advance. Lack of access to telecommunications and technology is understood as discrimination by people 

with disabilities and is perceived as a "digital divide." 

68 


accessibility 

Comment 




73 



Comment 


LABOR PRACTICES SCREENING AND ASSESSMENT > otherwise all screening and assessment indicators carry the same name 

73 



Comment 


We believe there should be more coverage of occuaptional safety and health within supply chain management reporting. 

73 

869 ASPECT: __SCREENING __ AND ASSESSMENT CORE G4 8 

SCREENING 

Comment 


This information would be difficult for a large, global organization to report on. 

Civil Society 

Organization 

Mediating 

Institution 

Europe 

Europe 

promote and 

enhance the 

disability 

disclosure in 


reports 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

Consultant 


Our members 

help 

organisations 

prepare and 

use 


reports 




Page 1459 of 2491


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73 



Comment 


Comment through 889-904:This information would be difficult for a large, global organization to report on. 

73 



Comment 



73 



Comment 


Supplier section is disproportionately focused on labor union-related content, without much emphasis on occupational health and 

safety. Output probably reflects imbalance in interests in working group. 

73 



Comment 


Generally, section is skewed to reflect interests of only certain group - disproportionately focused on labor unions without much 

emphasis on occupational health and safety. Output reflects imbalance in representation on the working group. 

73 


ASPECT: 

Comment 



73 


ASPECT: 

Comment 

Business 

Northern 

America 

Reporter 


Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 

Civil Society 

Organization 

Civil Society 

Organization 

Northern 

America 

Northern 

America 

Report Reader 

Report Reader 





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This information seems to be highly complex for a company such as Vale. 

73 

869-871 __ASPECT: SCREENING AND ASSESSMENT 

CORE G4 8 Percentage of new supplie... 



CORE G4 8 Percentage of new suppliers and other business partners screened for labor practices, and actions taken 

Comment 


This Aspect is repeatedly requested for each category (environment, social etc.). Since this a minimum requirement for reporting “in 

accordance with” G4 this will lead to uneconomical efforts. This can lead to a repeated and lengthy disclosure of similar information 

(e.g. in case management approaches are bundled for different topics in one system); also relevant for the other categories. 

73 





CORE G4 8 Percentage of new suppliers and other business partners screened for labor practices, 



Report the percentage of new suppliers and other business partners screened for labor practices, 






screening. 

Report the percentage of new suppliers and other business partners where performance expectations were set as a result of 

screening. 



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Report other actions taken to address the issues identified. 

Comment 


Line 869-904: This information would be difficult for a large, global organization to report on. 

73 


Mediating 

Institution 

Europe 

Reporter 

Report Reader 













Report the percentage of new suppliers and other business partners where performance expectations 

were set as a result of screening. 




CORE G4 9 Percentage of existing suppliers and other business partners identified as having actual 



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and potential adverse impacts for labor practices assessed on labor practices, and 

actions taken 



potential adverse impacts for labor practices, broken down by the location of the supplier and other 



impacts for labor practices, broken down by the location of the supplier and other business partner. 

For suppliers and other business partners identified as having actual and potential adverse impacts for 

labor practices: report the percentage of contracts that included clauses setting expectations on labor 

practices, broken down by the location of the supplier and other business partner. 


potential adverse impacts for labor practices that were assessed on labor practices, broken down by the location of the supplier and 






Comment 



73 










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actions taken 













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Replace 


his information would be difficult for a large, global organization to report on. 

73 





















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actions taken 

















Comment 



73 

870 AND ASSESSMENT CORE G4 8 __Percentage __ of new suppliers and other 

Percentage 

Comment 


Why only new suppliers and other business partners? 




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73 



Comment 


see comment above (CORE G4 5) 

73 



Comment 


870 CORE G4 8 Percentage of new suppliers and other business partners screened for labor practices, and actions taken 

Suggested Addition: number of businesses with whom a supply relationship has not commenced as a result of issues identified by 

screening 

73 



Comment 



73 



Comment 


This information would be difficult for a large, multi-site, global organization to collect and report on, as many organizations have 

thousands of suppliers and suppliers change often. 

73 

870-882 __Percentage of new suppliers and other business partners screened for l... 

Percentage of new suppliers and other business partners screened for labor practices, 







Mediating 

Institution 

Oceania 

Reporter 

Consultant 

Assurance 

Provider 

Report Reader 


Business 

Northern 

America 

Reporter 


Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 



Page 1467 of 2491


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screening. 


screening. 

Report the percentage of new suppliers and other business partners 

Comment 



73 

874-875 __broken down by the location of the supplier and other business partner... 



Replace 


broken down by the location of the supplier and other business partner AND FORMS OF SOCIAL AND ECONOMIC INCLUSION (SUCH 

AS SOCIAL BUSINESSES THAT EMPLOY PEOPLE WITH DISABILITIES) 


. SUPPLIERS INCLUDED AS “FORMS OF SOCIAL AND ECONOMIC INCLUSION”, BROKEN DOWN BY DIVERSITY GROUP 

Civil Society 

Organization 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

RATIONALE: 

The disclosure of forms of social and economic inclusion of suppliers and business partners broken down by diversity and/ or 

vulnerable group (differencing, among others, those social businesses that employ people with disabilities), would provide 

information on percentage of new suppliers and other business partners screened for labor practices that are integrated in other 

‘Forms of Social and Economic Inclusion’. 

73 

875 partner. Break down the following __four __ disclosures by: • The location 

four 

Replace 


three 

Mediating 

Institution 

Latin america 

Consultant 

Rationale: there are only 3 bullets 



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73 

877 • The nature of the __issue __ • The location of the 

issue 

Comment 


and how it will be handled. 

Mediating 

Institution 

Latin america 

Consultant 

Rationale: nature is not enough 

73 

884-900 __Report other actions taken to address the issues identified. 

CORE G4... 




actions taken 


Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 













Comment 





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73 


CORE G4 9 

Comment 




73 


CORE G4 9 Percentage of existing suppliers and other business partners identified as having actual and potential adverse impacts for 

labor practices assessed on labor practices, and 

actions taken 

Comment 



73 


Percentage of existing suppliers and other business partners identified as having actual and potential adverse impacts for labor 

practices assessed on labor practices, and 

actions taken 

Comment 


Not applicable where supply chain is within same country. Compliance with law of the land can only be sought 

73 




actions taken 

Comment 


see above 

73 




actions taken 

Comment 






Business 

Northern 

America 

Reporter 



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This information would be difficult for a large, multi-site, global organization to collect and report on, as many organizations have 

many thousands of suppliers. 

73 

886 as having actual and potential __adverse impacts __ for labor practices assessed on 


Comment 


This indicator is more relevant for a production company than a service company. 


Can GRI give some examples? 

73 

887 assessed on labor practices, and __actions __ taken [Standard Disclosure] Report the 

actions 

Comment 


see comment for G4 6, applies here as well 

73 

890-891 adverse impacts for labor practices, __broken down by the location of the supplier and other 

business partner. __ Report the percentage of total 

broken down by the location of the supplier and other 


Replace 


broken down by the location AND FORMS OF SOCIAL AND ECONOMIC INCLUSION of the supplier and other business partner (SUCH 


Mediating 

Institution 

Civil Society 

Organization 

Europe 

Europe 

Consultant 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

RATIONALE: 

The disclosure of the number of suppliers included as “Forms of Social and Economic inclusion” (differenciating, among others, 

those social business that employs people with disabilities), would be an effective tool to assess and monitor actual and / or 

potential adverse impacts for labor practices and actions taken refereed to that particular group. 

73 

893-894 adverse impacts for labor practices, __broken down by the location of the supplier and other business partner. __ For 

suppliers and other business 


Replace 




Civil Society 

Organization 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 



Page 1471 of 2491


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. 

RATIONALE: 

The disclosure of the percentage of forms of social and economic inclusion of suppliers and business partners (differenciating, 

among others, those social businesses that employs people with disabilities), would be an effective tool to assess if / how setting 

expectations on labor practices impacts on a greater engagement with particular forms of social and economic inclusion (such as 

sheltered workshops that employs people with disabilities). 

73 


four 

Replace 


three 

Mediating 

Institution 

Latin america 

Consultant 

Rationale: only three bullets detailed 

73 







Comment 



73 

903 supplier and other business partner __• __ The nature of the issue 

• 

Insert 


FORMS OF SOCIAL AND ECONOMIC INCLUSION (SUCH AS SOCIAL BUSINESSES THAT EMPLOY PEOPLE WITH DISABILITIES) 

RATIONALE: 

The disclosure of forms of social and economic inclusion of suppliers and business partners (differencing, among others, those social 

business that employs people with disabilities), would be an effective tool to assess the impact of the four reported issues on the 

different forms of social and economic groups versus others. 


Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 

Civil Society 

Organization 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 



Page 1472 of 2491


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74 

912 address the issues identified. ASPECT: __REMEDIATION __ [Standard Disclosure] CORE G4 10 

REMEDIATION 

Comment 


LABOR PRACTICES REMEDIATION > otherwise all remediation indicators carry the same name 

74 

914 CORE G4 10 Number of __grievances __ about labor practices filed, addressed, 

grievances 

Comment 







Mediating 

Institution 

Business 

Europe 

Northern 

America 

Consultant 

Reporter 



74 

914 [Standard Disclosure] CORE G4 10 __Number __ of grievances about labor practices 

Number 

Comment 


- Is it really the numbers that are of interest and not the reasons of the grievances? 

- Suggestion: rephrase the indicator to put more emphazis on the causes of the grievances. 

74 

914 identified. ASPECT: REMEDIATION [Standard Disclosure] __CORE G4 10 Number of grievances about labor practices filed, 

addressed, and resolved through __ formal grievance mechanisms Report the 

CORE G4 10 Number of grievances about labor practices filed, addressed, and resolved through 

Comment 







Mediating 

Institution 

Business 

Europe 

Northern 

America 

Consultant 

Reporter 



Page 1473 of 2491


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74 

914-915 __CORE G4 10 Number of grievances about labor practices filed, addressed... 


formal grievance mechanisms 

Comment 


see comment above (CORE G4 7) 

74 




Comment 










74 




Replace 












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74 




Comment 


Again - too detailed for realistic reporting at corporate level - is this really a core indicator (obligatory)? 

74 




Comment 







Mediating 

Institution 

Europe 

Consultant 

Assurance 

Provider 




74 

914-915 __Number of grievances about labor practices filed, addressed, and resol... 

Number of grievances about labor practices filed, addressed, and resolved through 


Comment 







Mediating 

Institution 

Europe 

Reporter 

Report Reader 



74 






Page 1475 of 2491


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Comment 


see above 

74 




Comment 








Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 



74 




Business 

Northern 

America 

Reporter 

Report the total number of grievances about labor practices filed through formal organizational 

grievance mechanisms, broken down by the nature and location of the grievance. 





o Gender 



Comment 



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74 

924 of underrepresented social groups o __Other indicators of diversity, if applicable __ Of the identified grievances, report 

Other indicators of diversity, if applicable 

Insert 


. OTHER DIVERSITY GROUPS (SUCH AS PEOPLE WITH DISABILITIES) 

RATIONALE: 

It is suggested to include the definition of Diversity Groups in the Glossary, with references to social groups that most likely forms 

part of Diversity (such as people with disabilities). 

Civil Society 

Organization 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

It is not easy to think on any group of population as an “indicator of diversity”, and specifically in this context as a subject that could 

“file a grievance”. 

76 




Remediation 


Report the availability and accessibility of grievance mechanisms and remediation processes, and the involvement of local 

community/workers’ representatives’ in monitoring their 



Comment 


Disclosure on human right incidents can only be reported when made known to DTAG. It is not possible to conduct research to 

detect human right incidents. 

76 



Civil Society 

Organization 

Europe 

Report Reader 

Work to 



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accessibility 

Comment 


The definbition of Accessibility should be included at Gglossary level 


76 

960 mechanisms and remediation processes. AND __PROCUREMENT __ PRACTICES 

PROCUREMENT 

Comment 


comment for HR1: shouldn't this be part of screening and assessment? 

77 

961 CORE HR2 Percentage of __significant __ suppliers, contractors, and other business 

significant 

Comment 


“significant” should not be deleted before “supplier” in this and the following indicators. 

77 

966 __Report the percentage of contracts with significant suppliers, contrac... 

Report the percentage of contracts with significant suppliers, contractors and other business partners 

Replace 



77 

969 result of human rights screening. __significant__ 

significant 

Comment 


I think this word should be left as is. It is very difficult for a multi-disciplinary company with thousands of suppliers to do this for all 

suppliers. Focus on the significant suppliers as a start. 

77 


significant 

Comment 



Mediating 

Institution 

Business 

Europe 

Northern 

America 

promote and 

enhance the 

disability 

disclosure in 


reports 

Consultant 

Reporter 






Page 1478 of 2491


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77 


significant 

Comment 



77 


significant 

Comment 


• CORE HR5/HR6 … (p. 77, line 969 ff) 

o The term „significant“ should not be eliminated, since this will lead to a substantial increase in report preparation time. Instead, 

the term “significant” should be clearly defined. 

77 


significant 

Comment 


“significant” should not be deleted before “supplier” in this and the following indicators as it would be too encompassing and 

onerous. 

77 


significant 

Comment 


significant” should not be deleted before “supplier” in this and the following indicators 

77 


significant 

Comment 



77 


significant 

Comment 

Business 

Northern 

America 

Reporter 


Mediating 

Institution 

Europe 

Reporter 

Report Reader 



Business 

Northern 

America 

Reporter 



Page 1479 of 2491


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significant” should not be deleted before “supplier” in this and the following indicators. 

77 


significant 

Comment 


The definition of suppliers will have a significant impact on the amount of data and the possibility to evaluate the data. Please 

specify. 

77 


significant 

Comment 



77 


significant 

Comment 



77 


significant 

Comment 


The term „significant“ should not be eliminated, since this will lead to a substantial increase in report preparation time. Instead, the 

term “significant” should be clearly defined. 

77 


significant 

Comment 



77 


significant 

Comment 





Business 

Northern 

America 

Reporter 


Gold Mining 

Company that 

reports in 



Page 1480 of 2491


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77 


significant 

Comment 



77 


significant 

Comment 



77 


significant 

Comment 


Vale suggests that “significant” should not be deleted before “supplier” due to the larger base of supplies for a global company such 

as Vale. 

77 


significant 

Comment 



78 

972 __significant __ significant 

significant 

Comment 




78 


significant 

Business 

Business 

Northern 

America 

Northern 

America 

accordance 

with the GRI 

Guideline 

Reporter 

Reporter 


Business 

Northern 

America 

Reporter 


Business 

Northern 

America 

Reporter 



Page 1481 of 2491


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Comment 



78 


significant 

Comment 


• CORE HR5/HR6 … (p. 77, line 969 ff) 

o The term „significant“ should not be eliminated, since this will lead to a substantial increase in report preparation time. Instead, 

the term “significant” should be clearly defined. 

78 


significant 

Comment 


CORE HR6 Operations and significant suppliers identified as having significant risk for incidents of 972 child labor, and measures 

taken to contribute to the effective abolition of child labor 

Clarification needed: the way this is worded makes it sound like the company should be impacting the wider societal circumstances 

that cause child labour; which while good is not what I think GRI intends – add within its supply chain to end of the sentence (same 

issue forced labor core requirement HR7) 

78 


significant 

Comment 


see above 

78 


significant 

Comment 



78 


significant 

Comment 



Mediating 

Institution 

Oceania 

Reporter 

Consultant 

Assurance 

Provider 

Report Reader 


Business 

Northern 

America 

Reporter 




Page 1482 of 2491


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as Vale. 

78 

974 significant __significant__ 

significant 

Comment 




78 


significant 

Comment 



78 


significant 

Comment 


see above 

78 


significant 

Comment 



78 


significant 

Comment 



as Vale. 

79 

977 ASPECT: __SCREENING AND __ CORE HR2 Percentage of new 

SCREENING AND 

Comment 


Business 

Northern 

America 

Reporter 


Business 

Northern 

America 

Reporter 


Mediating 

Institution 

Europe 

Consultant 



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HUMAN RIGHTS SCREENING AND ASSESSMENT (see rationale above) 

79 

977 ASPECT: __SCREENING __ AND CORE HR2 Percentage of 

SCREENING 

Comment 


We believe that HR 9 needs to be broader and encompass more than just being reactive to reporting incidents. We would like to 

see the following areas reported on that relate to Indigenous Peoples: 

Information 

Users 

Northern 

America 

Report Reader 

*Operations considered to have significant risk/exposure to Indigenous communities. 

* Policies that explicitly recognize or reference the UN Declaration on the Rights of Indigenous Peoples or ILO Conventions 107 and 

169. 

*Operations where free prior and informed consent (FPIC) applies, the number of projects that have failed FPIC review processes, 

and any projects that were pre-empted or discontinued as a result of such failure. 

*Measure and track indicators on Indigenous Peoples' community well-being (such as life expectancy, substance abuse, domestic 

violence, native language literacy and intensity of cultural practices) before, during and after projects. 

*The materials and training provided by the company to its employees on the rights of Indigenous People as recognized by ILO 

Conventions 107 and 169 and the UN Declaration on the Rights of Indigenous Peoples. 

*Materials and training a company provides to its employeees pertaining to the identity, language, community and cultural heritage 

of Indigenous Peoples. 

79 

977-979 __ASPECT: SCREENING AND 


CORE HR2 Percentage of new suppliers and other... 

ASPECT: SCREENING AND 

CORE HR2 Percentage of new suppliers and other business partners screened for human rights performance, and actions taken 

Comment 





79 

978 AND CORE HR2 Percentage of __new __ suppliers and other business partners 

new 

Comment 

Mediating 

Institution 

Europe 

Consultant 



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why new and not existing? 

79 

978 ASPECT: SCREENING AND __CORE HR2 __ Percentage of new suppliers and 

CORE HR2 

Comment 


Idem G4 5: review why are only about NEW suppliers, may IT go against the indicator of long-term contracts. sUGGESTION: % Of 

suppliers should be evaluated (remove term "new") 

79 

978-979 __CORE HR2 Percentage of new suppliers and other business partners scree... 


Comment 


These will add significant costs and of limited sustainibility materiality for organizations working within one country. Not viable 

79 



Comment 


see comment above 

79 



Comment 



79 

981-982 __Report the percentage of new suppliers and other business partners scr... 

Report the percentage of new suppliers and other business partners screened for human rights 


Comment 


This section should also include the number and percentage of suppliers and business partners to which the company's Indigenous 

Peoples' policies apply so there is greater transparency. 

79 


four 





Information 

Users 

Mediating 

Institution 

Northern 

America 

Latin america 

Report Reader 

Consultant 



Page 1485 of 2491


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Replace 


three 

Rationale: Only three bullets 

79 

984-986 __The location of the supplier and other business partner 

• The natur... 

The location of the supplier and other business partner 


• The location of the issue (if different 

Comment 


It seems to detailed information for a global company such as Vale. 

79 


• 

Insert 


. FORMS OF SOCIAL AND ECONOMIC INCLUSION (SUCH AS SOCIAL BUSINESSES THAT EMPLOY PEOPLE WITH DISABILITIES) 

RATIONALE: 


businesses that employ people with disabilities), would be an effective tool to assess the impact of the four reported issues on the 


79 

992 as a result of screening. __Report other actions taken to address the issues identified.__ 


Comment 


For Core HR 10, we believe that this area should address Indigenous Peoples' rights and include reporting on the total number and 

percentage of operations that have undergone cultural heritage, language,and sacred site assessments by country. 

80 

993 CORE G4 11 Percentage of __existing __ suppliers and other business partners 

existing 

Comment 


why only existing, is relevant for new suppliers as well! 


Civil Society 

Organization 

Information 

Users 

Mediating 

Institution 

Europe 

Northern 

America 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

Report Reader 

Consultant 



Page 1486 of 2491


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80 

993 CORE G4 11 __Percentage __ of existing suppliers and other 

Percentage 

Comment 


see comment G4 6 

80 

993 __CORE G4 11 __ Percentage of existing suppliers and 

CORE G4 11 

Comment 




80 

993 __CORE G4 11 __ Percentage of existing suppliers and 

CORE G4 11 

Comment 


Idem G4 6: difficulty of comparability, because there are different methodologies for impact assessment and depending on the 


80 

993-994 __CORE G4 11 Percentage of existing suppliers and other business partner... 


and potential adverse human 

Comment 


These will add significant costs and of limited sustainibility materiality for organizations working within one country. Once again 

need to remind to keep materiality & core indicator requirements in balance 

80 



and potential adverse human rights impacts assessed on human rights performance, and actions taken 

Comment 



80 


Percentage of existing suppliers and other business partners identified as having actual 

Mediating 

Institution 

Europe 

Consultant 








Page 1487 of 2491


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and potential adverse human rights impacts assessed on human rights performance, and actions taken 

Comment 


see above 

80 

994 as having actual and potential __adverse human rights __ impacts assessed on human rights 

adverse human rights 

Comment 


same question/remark as environmental performance. May be we need more guidance in identifing impacts 

80 

994 human rights impacts assessed on __human __ rights performance, and actions taken 

human 

Comment 


Can be reworded as " Percentage of existing supliers and other business partners identified as having adverse human rights impacts 

and actions taken. 

80 

1000 Report the percentage of total __existing suppliers and other business partners __ identified as having actual and 

existing suppliers and other business partners 

Comment 


This is - as we mentioned in our general comments - very unconcrete. Which level of supplier do you mean? Direct suppliers and 

business partners or also second-degree, third-degree etc. suppliers? 

80 

1003-1005 __For suppliers and other business partners identified as having actual ... 

For suppliers and other business partners identified as having actual and potential adverse human rights impacts: report the 

percentage of contracts that included clauses setting expectations on human rights, broken down by the location of the supplier or 


Comment 


We think that it is important to report on the percentage of contracts that include clauses on setting expectations on Indigenous 

Peoples' rights -- broken down by location of the supplier or other business partner. 

80 


four 

Replace 




Mediating 

Institution 

Information 

Users 

Mediating 

Institution 

Europe 

Northern 

America 

Latin america 

Consultant 

Report Reader 

for academic 

purposes 

Report Reader 

Consultant 



Page 1488 of 2491


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three 

Rationale: Three bullets instead of four 

80 


• 

Insert 



RATIONALE: 


businesses that employ people with disabilities), would be an effective tool to assess the impact of the four reported issues on the 

different forms of social and economic groups versus others 

81 

1043 CORE HR 11 Number of __grievances __ about human rights impacts filed, 

grievances 

Comment 







Civil Society 

Organization 

Business 

Europe 

Northern 

America 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

Reporter 



81 

1043-1044 __CORE HR 11 Number of grievances about human rights impacts filed, addr... 

CORE HR 11 Number of grievances about human rights impacts filed, addressed and resolved 


Comment 


see comment above 

81 








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Comment 








81 




Comment 







Business 

Northern 

America 

Reporter 



81 




Comment 












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81 

1043-1044 __Number of grievances about human rights impacts filed, addressed and r... 

Number of grievances about human rights impacts filed, addressed and resolved 


Comment 







Mediating 

Institution 

Europe 

Reporter 

Report Reader 



81 




Comment 


comment also for 785, 914, 1140:Please consider this response with all of the proposed new indicators on grievances (environment, 

human rights, labour practices, society). It is widely accepted in the human rights arena that reporting a number of grievances is 

meaningless. A low number may mean that a grievance mechanism is not functioning properly/the community is not aware of it 

etc. This was covered in extensive discussions during the development of the Mining and Metals Sector Supplement and the logic is 

supported by numerous human rights practitioners. 

Business 

Northern 

America 

Reporter 



81 




Comment 


see above 

81 





Gold Mining 

Company that 



Page 1491 of 2491


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Comment 







reports in 

accordance 

with the GRI 

Guideline 



81 




Business 

Northern 

America 

Reporter 


Report the total number of human rights grievances that were filed through formal organizational 

grievance mechanisms, broken down by the nature and location of the grievance. 





o Gender 



Comment 








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81 

1048-1054 __Report which of the following parties filed each grievance: 

Business 

Northern 

America 

Reporter 

• Inte... 





o Gender 



Comment 


Expanding on the point above, the CORE HR 11 indicator is essentially asking for twelve different pieces of information: 1) 

grievances filed, 2) addressed, 3) resolved; 4) held over from a previous reporting period; a breakdown of complainants by whether 

the complaint is 5) internal, 6) external or 7) a supplier, with further breakdowns by 8) gender, 9) membership of ‘underrepresented’ 

groups, 10) unspecified indicator(s) of ‘diversity’; and all of the above broken down by 11) the topic of the grievance 

and 12) the geographic location of the complainant. 

This level of disclosure is a miniature sustainability report in itself and creates a potentially significant reporting burden on 

companies for relatively little value added in terms of insight into performance. Imposing such a requirement could actually have 

the perverse effect of discouraging operations from using the grievance mechanism in order to avoid dealing with the added 

bureaucracy. This includes attempting to collect detailed information about complainants’ background (‘under-represented social 

groups’ and ‘other indicators of diversity’) could also have perverse consequences in terms of deterring complainants who may have 

legitimate reasons for not wishing to disclose this information. It is important to bear in mind that in some jurisdictions data 

protection and anti-discrimination laws may impose restrictions on gathering this kind of data in the first place. The result might be 

fewer grievances being handled overall – hardly a satisfactory outcome. 

It should also be noted that for commercial and legal reasons, reporting on grievances received from suppliers is problematic. In 



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addition, the indicator is not clear about reporting boundaries: is a company expected to report only on non-commercial grievances, 

or on all grievances? 

81 

1051 External stakeholders, including suppliers • __Individuals or groups of people identified by: __ o Gender o Membership of 

Individuals or groups of people identified by: 

Comment 


It is important to add disclosure on Indigenous Peoples here. Therefore, we suggest adding a bullet on any group of Indigenous or 

Aboriginal group as defined by the ILO or the UN Declaration on the rights of Indigenous Peoples. 

81 



Replace 



RATIONALE: 



Information 

Users 

Civil Society 

Organization 

Northern 

America 

Europe 

Report Reader 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 



81 

1060 the party that filed the __grievance.__ 

grievance. 

Comment 


Our suggestion is that the focus of the report should be about the effectiveness of the grievance mechanism allowing the proper 

monitoring of the cases. Additionally, the number of information required to be reported may be restrictive concerning the 

complainant´s confidentiality. 

83 




Remediation 


Report the availability and accessibility of grievance mechanisms and remediation processes, and the involvement of local 

community/workers’ representatives’ in monitoring their 





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Comment 





83 


accessibility 

Comment 




83 

1096 of grievance mechanisms and remediation __processes.__ 

processes. 

Comment 


Add a bullet point under Core SO1 to be more explicit around Indigenous Peoples and specify them by name. 

86 


CORE G4 12 Percentage of new suppli... 


Civil Society 

Organization 

Information 

Users 

Europe 

Northern 

America 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

Report Reader 


CORE G4 12 Percentage of new suppliers and other business partners screened for society-related performance, and actions taken 

Comment 





86 


CORE G4 12 

Comment 





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86 

1098 CORE G4 12 Percentage of __new __ suppliers and other business partners 

new 

Comment 


why new and not existing? 

86 

1098 other business partners screened for __society-related __ performance, and actions taken [Standard 

society-related 

Comment 


what is meant by society related oerformance? 

86 

1098-1099 __CORE G4 12 Percentage of new suppliers and other business partners scr... 


Comment 


These will add significant costs and of limited sustainibility materiality for organizations working within one country. Not do able 

86 



Comment 


see comment above. In addition "society-related" needs to be further defined 

86 



Comment 



86 

1101 other business partners screened for __society-related __ performance, broken down by location 


Comment 


This can be written as social initiatives taken and its performance 

Mediating 

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86 

1102 partners screened for society-related performance, __broken down by location of the supplier and other business partner. __ 

Break down the following four 

broken down by location of the supplier and other business partner. 

Replace 


broken down by location and FORMS OF SOCIAL AND ECONOMIC INCLUSION of the supplier and other business partner (SUCH AS 

SOCIAL BUSINESSES THAT EMPLOY PEOPLE WITH DISABILITIES) 

Civil Society 

Organization 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

RATIONALE: 

The provision of details of percentage of new suppliers and other business partners screened for society-related performance in 

social businesses that employs people with disabilities would provide relevant information on society-related performance and 

actions taken on them. 

86 


four 

Replace 


three 

86 


• 

Insert 



RATIONALE: 


businesses that employs people with disabilities), would be an effective tool to assess the impact of the four reported issues on the 

different forms of social and economic groups versus others 

86 

1113 CORE G4 13 Percentage of __existing __ suppliers and other business partners 

existing 

Comment 


why only existing and not new? 

86 

1113 suppliers and other business partners __identified __ as having actual and potential 

Mediating 

Institution 

Civil Society 

Organization 

Mediating 

Institution 

Mediating 

Institution 

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enhance the 

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disclosure in 


reports 

Consultant 

Consultant 



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identified 

Comment 


see comment G4 6 

86 


CORE G4 13 

Comment 




86 



and potential adverse 

Comment 


These will add significant costs and of limited sustainibility materiality for organizations working within one country 

86 



and potential adverse impacts on society assessed on society-related performance, and actions taken 

Comment 



86 



and potential adverse impacts on society assessed on society-related performance, and actions taken 

Comment 


see above 

86 

1118 having actual and potential adverse __impacts on society, __ broken down by the location 

impacts on society, 

Comment 






Business 

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"Impacts on society" is such a vague and undefined concept, it leaves too much leeway to the reporting organization: any data 

gathered here will not be comparable or relevant. 

86 

1118-1119 society, broken down by the __location of the supplier and other business 

partner. __ Report the percentage of total 

location of the supplier and other business 

partner. 

Comment 


Do not see how this is relevant - the location is difficult to determine and might be confidential and that are other business partners 

86 

1121 having actual and potential adverse __impacts on society, __ broken down by the location 

impacts on society, 

Comment 


"Impacts on society" is such a vague and undefined concept, it leaves too much leeway to the reporting organization: any data 

gathered here will not be comparable or relevant. 

87 

1140 14 Number of grievances about __society-related __ impacts filed, addressed, and resolved 


Comment 


what is meant by society related impacts? 

87 

1140 CORE G4 14 Number of __grievances __ about society-related impacts filed, addressed, 

grievances 

Comment 








Business 

Mediating 

Institution 

Business 

Northern 

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Europe 

Northern 

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Reporter 

Consultant 

Reporter 



87 

1140 to address the issues identified. __CORE __ G4 14 Number of grievances 




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CORE 

Comment 









87 

1140-1141 __CORE G4 14 Number of grievances about society-related impacts filed, a... 

CORE G4 14 Number of grievances about society-related impacts filed, addressed, and resolved 


Comment 









87 




Comment 












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87 




Comment 


see above 

87 




Comment 


REf. also line 785, 914 and 1043: Please consider this response with all of the proposed new indicators on grievances (environment, 

human rights, labour practices, society). It is widely accepted in the human rights arena that reporting a number of grievances is 

meaningless. A low number may mean that a grievance mechanism is not functioning properly/the community is not aware of it 

etc. This was covered in extensive discussions during the development of the Mining and Metals Sector Supplement and the logic is 

supported by numerous human rights practitioners. 





87 




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87 



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Comment 









87 




Comment 










87 

1140-1141 __Number of grievances about society-related impacts filed, addressed, a... 

Number of grievances about society-related impacts filed, addressed, and resolved 


Comment 







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87 




Comment 










87 




Comment 







Business 

Northern 

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87 




Comment 





Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 



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87 

1143-1151 __Report the total number of grievances about society-related impacts fi... 

Report the total number of grievances about society-related impacts filed through formal organizational grievance mechanisms, 


Business 

Northern 

America 

Reporter 





o Gender 



Comment 









87 

1148 External stakeholders, including suppliers • __Individuals or groups of people identified by: __ o Gender o Membership of 

Individuals or groups of people identified by: 

Comment 


Be more explicit about how Indigenous Peoples are impacted by adding another bullet point here: 

Information 

Users 

Northern 

America 

Report Reader 



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*Any Indigenous or Aboriginal Group as defined by the ILO or the UN Declaration on the Rights on Indigenous Peoples. 

87 



Replace 


OTHER DIVERSITY GROUPS (SUCH AS PEOPLE WITH DISABILITIES) 

RATIONALE: 




“file a grievance" 

111 

1220 ASPECT: PROCUREMENT PRACTICES CORE EC6 __Spending __ on locally-owned suppliers broken down 

Spending 

Comment 


Again, spending is a non-ideal indicator. Spendings depend on market price fluctuations and usually confidential and competition 

sensitive individual price agreements, which in turn depend on various factors incl. capacity utilisation and volumes. Suggested unit: 

volumes produced in pieces or weight. 

111 


EC6 

Comment 


see previous comments on the initial section which mentions the EC6 indicator 

111 

1220 ASPECT: PROCUREMENT PRACTICES __CORE EC6 __ Spending on locally-owned suppliers broken 

CORE EC6 

Comment 




111 


locally-owned 

Civil Society 

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Report Reader 

Work to 

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disclosure in 


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Comment 


local 

111 



Replace 


Spending on locally-owned suppliers broken down by forms of SOCIAL AND economic inclusion, at significant locations of operation. 

RATIONALE: 

Making reference to social and economic inclusion remarks the importance of both concepts as relevant forms/components of 

inclusion. 

111 


locally-owned 

Comment 


local 

111 

1225 operation. Provide information on how __locally-owned __ suppliers and significant locations of 

locally-owned 

Comment 


local 

111 


locally-owned 

Comment 


local 

111 


locally-owned 

Comment 


local 

Civil Society 

Organization 

Mediating 

Institution 

Mediating 

Institution 

Mediating 

Institution 

Mediating 

Institution 

Europe 

Europe 

Europe 

Europe 

Europe 

Assurance 

Provider 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

Reporter 

Consultant 

Assurance 

Provider 

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Provider 

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Consultant 

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111 

1234 of economic inclusion’. [Guidance] Relevance __By supporting local business __ in the supply chain, an 

By supporting local business 

Comment 


How to align this with European procurement legislation regarding tenders? 

111 

1240 identify the percentage spent on __locally-owned __ suppliers. Local purchases can be 

locally-owned 

Comment 


local 

111 

1244 accruals accounting). ‘Other forms of __economic __ inclusion’ may include but are 

economic 

Comment 


o Line 1244 ff: “Other forms of economic inclusion”: This might not feasible for large multinationals. If an organizations has 100.000 

suppliers it will not be able to ask for such detailed information. 

111 

1244 commitments made (e.g., accruals accounting). __‘Other forms of economic inclusion’ __ may include but are not 

‘Other forms of economic inclusion’ 

Comment 


This might not feasible for large multinationals. If an organizations has 100.000 suppliers it will not be able to ask for such detailed 

information. 

111 

1244-1247 __‘Other forms of economic inclusion’ may include but are not limite... 

‘Other forms of economic inclusion’ may include but are not limited to: 

• suppliers owned by women 

• suppliers owned or staffed by members of vulnerable, marginalized or underrepresented social groups 

Replace 


Forms of SOCIAL AND economic inclusion’ may include but are not limited to: 

• suppliers owned by women 

. SUPPLIERS OWNED OR STAFFED BY PEOPLE WITH DISABILITIES 

• suppliers owned or staffed by OTHER members of vulnerable, marginalized or underrepresented social groups 


Mediating 

Institution 

Europe 

Reporter 

Consultant 

Assurance 

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Civil Society 

Organization 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


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RATIONALE: 

Making reference to ‘Forms of Social and Economic inclusion’ remarks the importance of both concepts as relevant components of 

inclusion. 

Reporting specifically about suppliers owned or staffed by people with disabilities is a way of extending organizations commitment 

to people with disabilities as relevant stakeholders to their value chains. 

Organizations should disclose at this level not only because of the inherent social risks and the governance challenges the supply 

chain poses, but also because of the many rewards it can deliver. There is increasing legislation favoring goods and services 

providers that comply with employment regulations for people with disabilities, or foster special measures addressed to people with 

disabilities, in public procurement. 

It supports also accountability on compliance of a particular legislation (e.g. legislation that establish quota for employment of 

people with disabilities) and as means of benchmarking in social and economic inclusion performance. 

112 

1251-1252 __Definitions 

ECONOMIC INCLUSION __ For the purpose of this 

Definitions 

ECONOMIC INCLUSION 

Replace 


COMMENT: 

It is suggested to make a more general definition (Economic and Social Inclusion) to homogenize the use of this concept and align 

with the use of other Forms of Social and Economic Inclusion, which should include an explicit reference to people with disabilities. 

112 

1257 small and medium sized suppliers. __LOCALLY-OWNED SUPPLIER __ A supplier owned by persons 

LOCALLY-OWNED SUPPLIER 

Comment 


Many organizations track and manage their share of local sourcing, but not with regard to “local ownership”. 

This would require a definition of “locally owned”. Does it refer to a company led or in possession of locals? 

Tracking this information would require additional data not relevant for steering the business. 

112 

1257 small and medium sized suppliers. __LOCALLY-OWNED __ SUPPLIER A supplier owned by 

LOCALLY-OWNED 

Comment 

Civil Society 

Organization 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 





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o Line 1257 ff: “Locally-owned supplier”: Many organizations track and manage their share of local sourcing, but not with regard to 

“local ownership”. This would require a definition of “locally owned”. Does it refer to a company led or in possession of locals? 

Tracking this information would require additional data not relevant for steering the business. 

112 

1257 small and medium sized suppliers. __LOCALLY-OWNED __ SUPPLIER A supplier owned by 

LOCALLY-OWNED 

Comment 


Local 

112 

1261 city, a region, or country. __SIGNIFICANT LOCATIONS OF OPERATION __ Locations where single-market revenues, costs, 

SIGNIFICANT LOCATIONS OF OPERATION 

Comment 


"Significant locations of operations” might have nothing to do with the importance of the supplier. 

112 

1261 city, a region, or country. __SIGNIFICANT __ LOCATIONS OF OPERATION Locations where 

SIGNIFICANT 

Comment 


o Line 1261 ff: “Significant locations of operations” might have nothing to do with the importance of the supplier. 

113 

1275 ASPECT: PROCUREMENT PRACTICES __CORE G4 1 Spending on suppliers with which long-term agreements exist __ [Standard 

Disclosure] Compilation Report the 


Comment 


Believe this indicator needs a complete re-think. A long term agreement is not 1 year and doubt whether such detailed information 

is relevant or useful for most stakeholders 

113 

1275 ASPECT: PROCUREMENT PRACTICES __CORE G4 1 Spending on suppliers with which long-term agreements exist __ [Standard 

Disclosure] Compilation Report the 


Comment 


Lines 1275-1332 

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G4.1 and G4.2 have the same relevance, and two indicators is unnecessary. If long-term agreements are not in place, then clearly 

short-term or new agreements dominate. G4.2 is based on number of suppliers without regard to size and is therefore difficult to 

interpret, and could be dropped. 

113 

1275 ASPECT: PROCUREMENT PRACTICES __CORE G4 1 __ Spending on suppliers with which 

CORE G4 1 

Comment 




113 

1275 PROCUREMENT PRACTICES CORE G4 1 __Spending __ on suppliers with which long-term 

Spending 

Comment 


Volumes produced instead of spendings. Spendings can be affected by various factors. Effective capacity planning instead is most 

crucial to most suppliers. Spendings, other than volumes, might additionally bring up confidentiality issues. 

113 

1295-1296 __LONG-TERM AGREEMENT 

A contractual agreement that exceeds a single or... 

LONG-TERM AGREEMENT 

A contractual agreement that exceeds a single order and extends beyond the reporting period. 

Comment 


To us this is not a good definition of long-term agreement. If an organization places an order in November and that organization 

reports in December - to us this is not a long-term agreement. 

To us a long-term agreement is a contractual agreement that exceeds at least three orders. 



Mediating 

Institution 

Europe 

Consultant 

Report Reader 

for academic 

purposes 

You use the term "long-term agreement" already on page 53, but you define it on page 113 - this is irritating. Why don´t you define 

it in the glossary of terms? 

114 

1303-1316 __ASPECT: PROCUREMENT PRACTICES 

Business 

Northern 

America 

Reporter 

CORE G4 2 Percentage of suppliers with... 

ASPECT: PROCUREMENT PRACTICES 



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Compilation 

Report the percentage of total suppliers with which orders were placed for the first time during the 

reporting period. 

[Guidance] 

Relevance 

This Indicator helps quantify the stability of an organization’s supplier base. A high turnover of suppliers may indicate that supplier 

selection or relationship management are ineffective, undermining the 

organization’s ability to effect sustainability improvements. A low turnover may indicate that an 

organization is not assessing supplier performance adequately, or enabling wealth creation by exercising its buying power widely. 

Comment 


This indicator and related guidance is not fit for purpose. As noted in the guidance for this indicator, “This Indicator helps quantify 

the stability of an organization’s supplier base. A high turnover of suppliers may indicate that supplier selection or relationship 

management are ineffective, undermining the organization’s ability to effect sustainability improvements. A low turnover may 

indicate that an organization is not assessing supplier performance adequately, or enabling wealth creation by exercising its buying 

power widely.” Thus the disclosure would be meaningless. 

Furthermore, both the maturity of a particular operation as well as the remoteness and availability of supplier options would tend 

to skew the data in various directions given the circumstances. Thus the trends in the reported data could have absolutely nothing 

to do with the reasons given as to why this is a relevant disclosure 

114 

1304 ASPECT: PROCUREMENT PRACTICES __CORE G4 2 __ Percentage of suppliers with which 

CORE G4 2 

Comment 




114 

1304 ASPECT: PROCUREMENT PRACTICES __CORE __ G4 2 Percentage of suppliers 





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CORE 

Comment 








to skew the data in various directions given the circumstances. Thus the trends in the reported data could have nothing to do with 

the reasons given as to why this is a relevant disclosure. 

114 



Comment 


What signifiance does this core indicator have? We believe it is more interesting to know, in which field lots of changes take place. 

114 



Comment 


What is the relevance to sustainability and what makes it core? 

114 



Comment 







Mediating 

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for academic 

purposes 








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114 



Comment 


see comment on G4.1 Same applies here 

114 



Comment 










114 



Comment 


Lines 1275-1332 

Mediating 

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Northern 

America 

Consultant 

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Provider 

Reporter 

Reporter 

G4.1 and G4.2 have the same relevance, and two indicators is unnecessary. If long-term agreements are not in place, then clearly 

short-term or new agreements dominate. G4.2 is based on number of suppliers without regard to size and is therefore difficult to 

interpret, and could be dropped. 

114 



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114 

1304-1305 __Percentage of suppliers with which orders were placed for the first ti... 

Percentage of suppliers with which orders were placed for the first time during the reporting period 

Comment 










114 



Comment 









Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 




114 



Comment 


Business 

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114 





Compilation 



[Guidance] 

Relevance 




organization 

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114 




Compilation 



[Guidance] 

Relevance 





Comment 







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[Guidance] 

Relevance 





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[Guidance] 

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[Guidance] 

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Comment 





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to skew the data in various directions given the circumstances. Thus the trends in the reported data could have absolutely nothing 

to do with the reasons given as to why this is a relevant disclosure. 

114 





Compilation 



[Guidance] 

Relevance 





Replace 












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114 

1305 first time during the reporting __period __ [Standard Disclosure] Compilation Report the 

period 

Comment 







Business 

Northern 

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Reporter 




114 

1306-1316 __[Standard Disclosure] 

Compilation 

Report the percentage of total s... 



Gold Mining 

Company that 

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with the GRI 

Guideline 

Compilation 



[Guidance] 

Relevance 





Comment 





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114 

1308-1309 __Report the percentage of total suppliers with which orders were placed... 



Comment 


We have noticed that the breakdown of locations and countries do not feature here! is this an indication that such information is 

not that relevant and simply adds to the burden? This is a general comment also for the G4 Indicator disclosures 

114 

1311 during the reporting period. [Guidance] __Relevance __ This Indicator helps quantify the 

Relevance 

Comment 


- This figure seems to be really difficult to interprete (comparablilty principle). Other reasons for changes are changes in the 

purchasing strategy, changes in the needs (e.g. input material), because the former supplier went out of business, etc. 

- Suggestion: delete this indicator. 

114 

1312 the reporting period. [Guidance] Relevance __This Indicator helps quantify the stability of an organization’s supplier base. A 

__ high turnover of suppliers may 

This Indicator helps quantify the stability of an organization’s supplier base. A 

Comment 


There can be a high percentage of new suppliers every year without any impact on stability of relations with existing suppliers. This 

can simply be caused by growth, addition of new product categories etc. Also, when growing and accordingly sourcing for new 

production capacity, as part of a screening and evaluation process of potential new suppliers, businesses might place test orders 

with new suppliers which will after this assessment not become long-term suppliers due to unsatisfactory performance incl. against 

sustainability requirements. This naturally increases the number of "new suppliers" according to below definition, but again does 

not tell anything about stability in supplier relations. A more reasonable indicator could be "Average length of relations with 

significant suppliers". 

Mediating 

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Reporter 

Consultant 

Report Reader 

GRI Certified 

Training 

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114 

1312-1316 __This Indicator helps quantify the stability of an organization’s sup... 





Comment 


This is certainly presumptious. To repeat do not mistake purpose for a known way of doing things 

115 

1334 ASPECT: PROCUREMENT PRACTICES __CORE G4 3 Time taken to pay suppliers __ [Standard Disclosure] Compilation Report 

the 


Comment 


This has nothing to do with susuainability and 

would also not be a sufficiently reliable 

indicator to predicr any issues with paying eg 

workers. Furthermore this is covered by the 

annual report 

115 

1334 ASPECT: PROCUREMENT PRACTICES __CORE G4 3 __ Time taken to pay suppliers 

CORE G4 3 

Comment 




115 

1338 to suppliers that were made __late. __ [Guidance] Relevance This Indicator identifies 

late. 

Comment 


What do you mean by "late" - what is "late"? 

115 

1346 paid. Identify the number of __days __ taken to pay each supplier 

days 

Comment 



Mediating 

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Mediating 

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Mediating 

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for academic 

purposes 

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- Might be difficult for small companies, which don't have an advanced ERP system to automatically track the date of acceptance. 

Suggestion: Delete the calculation of average number of days, but leave the calculation of late payments. 

115 

1351 of payments that were made __late __ to suppliers. Late payments are 

late 

Comment 


- Payments may also delay, because the delivery/or the invoice itself is wrong. 

- Would a ratio (volume, %)not be more interesting than the actual number? 

- Suggestion: rephrase the indicator 

116 

1361 ADD G4 4 Percentage of __monetary value of __ each type of materials, products 

monetary value of 

Comment 


Monetary value depends on market price development and does not allow fair conclusions on impact reductions by material, 

product or service choices. Prices for materials, products and services naturally depend on volumes and high volumes are what 

reduces impacts. Choosing monetary value as indicator creates incomparabilities and tends to benefit small-scale solutions. 

116 

1361 ASPECT: PROCUREMENT PRACTICES __ADD G4 4 __ Percentage of monetary value of 

ADD G4 4 

Comment 




116 


ADD G4 4 Percentage of monetary value of each type of materials, products and services purchased that have been verified or 

certified as 

being in accordance with credible, widely-recognized economic, 

environmental and social standards 

Comment 


Seeking a raw material, product or service that is certified by a “widely recognized standard” would only be logical if the material, 

product, or service is linked to an issue that has been identified as material to the reporting organization. Otherwise, the company 

is unlikely to commit the resources to track such certifications. 

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Institution 

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The text indicates on line 1372 and 1373 that standards have been developed for a “large number of materials, products, and 

services” yet there are no references provided on Line 1398. This information would beneficial to provide a reporting organization. 

116 


ADD G4 4 Percentage of monetary value of each type of materials, products and services purchased that have been verified or 

certified as 


environmental and social standards 

Comment 





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116 

1365 economic, environmental and social standards __[Standard Disclosure] __ Compilation For each type of 


Comment 








116 

1366 and social standards [Standard Disclosure] __Compilation __ For each type of material, 

Compilation 

Comment 


comment for 1366-1393 and 1394-1398:Seeking a raw material, product or service that is certified by a “widely recognized 

standard” would only be logical if the material, product, or service is linked to an issue that has been identified as material to the 

reporting organization. Otherwise, the company is unlikely to commit the resources to track such certifications. 

Business 

Northern 

America 

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116 

1366 and social standards [Standard Disclosure] __Compilation __ For each type of material, 

Compilation 

Comment 





116 

1366-1369 __Compilation 

For each type of material, product or service purchased,... 

Compilation 


certified as being in accordance with credible, widely-recognized economic, 

environmental and social standards, broken down by standard. 

Comment 





116 



Compilation 

Business 

Northern 

America 

Reporter 


Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 

Business 

Northern 

America 

Reporter 




Comment 


G4.4 This is a big task for companies with diverse and complex supply chains in many different jurisdictions. It is very onerous to 

report and of questionable value, given an absence of materiality context. Describing an organisation’s management approach to 

purchasing certified materials would provide insight without the need for such data. 

116 





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Compilation 




Comment 






services” yet there are no references provided on Line 1398. This information would be beneficial to provide to a reporting 

organization. 

116 




Compilation 




[Guidance] 

Relevance 

Credible, widely-recognized economic, environmental and social standards have been developed for a large number of materials, 

products and services. Detailed sustainability requirements are included in these standards. These standards enable organizations to 

demonstrate sustainable procurement 

Comment 



product, or service is linked to an issue that has been identified as material to the reporting organization. Otherwise, the company is 

unlikely to commit the resources to track such certifications. 



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116 


Business 

Northern 

America 

Reporter 


Compilation 

For each type of material, product or service purchased, report the percentage of the monetary value 

that has been verified or certified as being in accordance with credible, widely-recognized economic, 


[Guidance] 

Relevance 

Credible, widely-recognized economic, environmental and social standards have been developed for a 

large number of materials, products and services. Detailed sustainability requirements are included in 

these standards. These standards enable organizations to demonstrate sustainable procurement 

practices. 

Methodology for data collection 

Identify the types of materials, products and services purchased. Examples of types of materials, 

products and services include timber, metals, coffee, and manual labor. 

Identify the total monetary value of each of these types of materials, products and services. 

Identify the types and monetary value of materials, products and services purchased that have been 

verified or certified in accordance with credible, widely-recognized economic, environmental and social 

Comment 







Page 1527 of 2491


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116 



Compilation 




[Guidance] 

Relevance 




practices. 







standards. 

For each type, calculate the certified percentage of total monetary value by using the following formula: Total monetary value of a 

type of material,product and service purchased verified or certified 

as being in accordance with credible,widely−recognized economic,environmental and social standards 

Total monetary value of the type of material,product and service purchased X 100 

Comment 


Mediating 

Institution 

Europe 

Reporter 

Report Reader 



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116 




Compilation 




[Guidance] 

Relevance 




practices. 







standards. 





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as being in accordance with credible,widely−recognized economic,environmental and social 

Comment 


Line 1366-1398: Seeking a raw material, product or service that is certified by a “widely recognized standard” would only be logical 

if the material, product, or service is linked to an issue that has been identified as material to the reporting organization. Otherwise, 

the company is unlikely to commit the resources to track such certifications. 


services” yet there are no references provided on Line 1398. This information would be beneficial to provide a reporting 

organization. 

116 




Compilation 




[Guidance] 

Relevance 




practices. 









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standards. 





= Percentage of total monetary value for each type of material, product and service purchased that has been verified or certified as 


environmental and social standards. 

Definitions 

CREDIBLE, WIDELY-RECOGNIZED ECONOMIC, ENVIRONMENTAL AND SOCIAL STANDARDS 

A set of criteria on economic, environmental and social qualities which has been developed using a 

collaborative, representative, robust and transparent process, and which is subject to verification or 

certification by a representative body. A body verifying or certifying the standard must work to rules and be accountable for 

following those rules, and be independent of the reporting organization. 

Replace 







116 





Business 

Northern 

America 

Reporter 

[Guidance] 

Relevance 




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practices. 







standards. 





= Percentage of total monetary value for each type of material, product and service purchased that has been verified or certified as 


environmental and social standards. 

Definitions 






Comment 







Page 1532 of 2491


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116 

1372-1373 __Credible, widely-recognized economic, environmental and social standar... 

Credible, widely-recognized economic, environmental and social standards have been developed for a large number of materials, 

products and services. Detailed sustainability requirements are included in 

Comment 




116 

1380-1382 __Identify the types and monetary value of materials, products and servi... 



standards. 

Comment 


Regarding disability, besides references of international initiatives, such as United Nation Convention on the Rights of People with 

disabilities (2006), it would be advisable to provide references of some legislation and standards that could be considered by 

organizations to support broader accountability and transparence on that particular topic. 


Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 

Civil Society 

Organization 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

Taking in account that many people with disabilities still face difficulties in their everyday lives associated to the use of different kind 

of products and services, there are new market opportunities for products and services that are accessible and designed for all, and 

its verification or certification according to accessibility standards (more common in ICT or Construction sectors) would be also of 

great help to assure their accessibility performance. As stated in the roadmap of the European Accessibility Act (expected to be 

adopted by the end of 2012): “Given the correlation between disability and ageing, and the demographic change in Europe, it is 

expected that over 20% of the EU population would benefit from improvements in accessibility of goods and services”. 

116 

1388-1393 __Definitions 

CREDIBLE, WIDELY-RECOGNIZED ECONOMIC, ENVIRONMENTAL AND ... 

Definitions 

Mediating 

Institution 

Europe 

Report Reader 


Standards 

Member 

Organisation 







Page 1533 of 2491


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Comment 


The ISEAL Alliance encourages the GRI to more adequately define or interpret what constitutes a "credible, widely-recognised 

economic, environmental and social standard". While the current definition presented in the GRI 4 Exposure Draft states that the 

standard used should have been developed in a “collaborative, representative, transparent and robust” manner and that the body 

verifying compliance with the standard should be independent of the reporting organisation, we believe further guidance is needed 

on what constitutes a “credible, widely-recognised economic, environmental and social standard.” 

The ISEAL Alliance is the global association for sustainability standards. Its members can be considered the leading international 

sustainability standards – organisations such as the Forest Stewardship Council (FSC), Marine Stewardship Council (MSC) and 

Fairtrade. As a collective, one of the major questions the ISEAL Alliance is tasked with addressing is : what makes a standard 

credible? 

ISEAL works from the belief that the ultimate aim of a credible sustainability standard should be to bring about positive social, 

environmental and economic impacts. A standard that has achieved its desired impacts is able to demonstrate, for one, that it 

brings about meaningful change on the ground (performance), and second, that there is uptake of the standard by a wide range of 

users, along the whole supply chain (uptake). 

To make this idea of credibility and its constituent elements performance and uptake more tangible, ISEAL is currently leading an 

inclusive global conversation to reach consensus on the core values and characteristics that underpin credible standards. These 

principles, currently in draft form, are intended to be an international reference – a signpost that directs decision-makers in their 

purchasing and sourcing decisions and their engagement with sustainability standards. 

ISEAL Draft Credibility Principles (see http://www.isealalliance.org/our-work/defining-credibility/our-credibility-principles) 

A. Performance 

The draft principles under the performance category are: 

1. Effectiveness: Does the standard have a programme in place for monitoring and evaluating impacts integrating this learning into 

improvements of the standard? 

2. Relevance: Are the highly important social and environmental challenges faced by the sector or industry being addressed by the 

standard? 

3. Rigour: Does the standard reflect best scientific understanding and does it reference relevant international norms? Does it require 

performance that measurable improves on the status quo? 

4. Accuracy: Does the standard have a well-functioning system in place for providing an accurate picture of whether a producer or 

enterprise is in compliance with requirements? 

5. Impartiality: Are assessments of compliance objective such that there are no conflicts of interest and auditor and audit process 

are not inappropriately influenced in their decisions? 

6. Co-ordination: Does the standard build on existing standards where relevant and collaborate with other standards systems to 

improve consistency and efficiency in operating practices? 

7. Operational Efficiency: Does the standard have a sound business and financial model in place as well as an efficient governance 

system? 

B. Uptake 



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The draft principles under the uptake category are: 

8. Engagement: Was a representative group of stakeholders involved in the standards development process and are relevant 

stakeholders engaged in the assurance and impacts evaluation? 

9. Transparency: Is there accessible information about the content of the standard and the certification process, sustainability 

impacts and the various ways that stakeholders can engage? 

10. Truthfulness: Are claims and communications about the standard easy to understand, accurate about benefits and precise in 

their language? 

11. Accountability: Does the standard have an independent complaints mechanism in place regarding its own activities and those of 

assurance providers? 

12. Accessibility: Is the standard equally applicable to all types of enterprises? Bearing in mind the end-user, is the assurance 

process no more onerous than necessary? 

13. Capacity: Does the standards systems facilitate training and access to resources for enterprises seeking assurance and to 

develop local assurance provision? 

With this as background we propose the following change: 

Definitions 

CREDIBLE, WIDELY-RECOGNISED ECONOMIC, ENVIRONMENTAL AND SOCIAL STANDARD 

“A set of criteria on economic, environmental and social qualities that has been developed, implemented and verified in such a way 

that it is consistent with each of the ISEAL Alliance’s Credibility Principles. “ 

117 

1394 __Documentation __ Potential sources of information include 

Documentation 

Comment 








117 

1394-1395 __Documentation 

Business 

Northern 

America 

Reporter 

Potential sources of information __ include self-assessment reports, verification reports, 

Documentation 

Potential sources of information 

Comment 




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117 



Potential sources of information include self-assessme... 

Documentation 

Potential sources of information include self-assessment reports, verification reports, purchasing orders, delivery orders, bills and 

certificates. 

Comment 






services” yet there are no references provided on Line 1398. This information would be beneficial to provide to a reporting 

organization. 

117 



Potential sources of information include self-assessme... 

Documentation 

Potential sources of information include self-assessment reports, verification reports, purchasing orders, delivery orders, bills and 

certificates. 

References 

None. 

Replace 





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117 

1398 orders, bills and certificates. References __None.__ 

None. 

Comment 




117 

1398 orders, bills and certificates. References __None.__ 

None. 

Comment 




177 



Comment 


G4.5 & 4.6 & 4.7 Not clear why these indicators focus on only environmental performance and impacts for suppliers, and for 

grievances, rather than wider sustainability performance including health and safety, social responsibility, business ethics, product 

quality etc. The same argument applies to G4.8, G4.9 and G4.10 which parallel the environmental indicators for labour practices, 

and for human rights in G4.11, HR2 and HR11, and for G4.12, G4.13 and G4.14 for society-related performance. In general 

organisations should not manage these separately. It should be possible to reduce these to only three or even two more insightful 

indicators. 

177 

1415 result of screening. Report the __percentage __ of new suppliers and other 

percentage 

Comment 


- Percentage with respect to what? All accepted suppliers, all potential suppliers from which the organization received a 

quote/offer? 


Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 


America 

Business 

Mediating 

Institution 

Northern 

America 

Europe 

Reporter 

Consultant 



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- Often the not-selected suppliers are not registered in an ERP system. It might therefore be challenging to collect the required 

material. 

179 

1449 ASPECT: SCREENING AND ASSESSMENT __CORE G4 6 __ Percentage of existing suppliers and 

CORE G4 6 

Comment 




179 


CORE G4 6 Percentage of existing suppliers and other business partners 

identified as having actual and potential adverse impacts on the 

environment assessed on environmental performance, and actions taken 

Comment 







indicators. 

179 

1449-1452 __Percentage of existing suppliers and other business partners 

identifi... 

Percentage of existing suppliers and other business partners 



Comment 


All businesses will have adverse impacts which have to be mitigated / addressed. Listing out all actual and potential risks will 

increase vulnerability 

179 


identifi... 





Business 

Northern 

America 

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Mediating 

Institution 

Europe 

Consultant 

Assurance 

Provider 



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Comment 


EVERY company has a potential adverse 

impact on the environment. This should be 

related to the material issues for the 

reporting company and should be assessed on 

their (potential) material impact on these 

issues too before being includd in this aspect 

179 

1450 as having actual and potential __adverse impacts on __ the environment assessed on environmental 

adverse impacts on 

Comment 


"adverse impacts" might require clearer definition. As practically any business has some actual or potential adverse impact on the 

world around it, reporting against this indicator would realistically require a 100% ratio for reporting organisation. 

179 





Business 

Northern 

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Reporter 




Comment 


G4.6 and G4.9 and G4.11 - The break-down required is highly burdensome. If specific impacts are highly material, reporting 

organisations should already be separately reporting these, otherwise data can be consolidated rather than broken down to create 

masses of detailed, and probably redundant, data related to non-material impacts. Suggest “For highly material or significant 

supplier impacts, describe the impact, including nature, locations and responding actions related to the issue.” 

180 

1487-1489 __Identify the total number of suppliers and other business partners tha... 

Identify the total number of suppliers and other business partners that were active during the reporting period, broken down by the 

location of the supplier and other business partner. Active suppliers are 

those from which materials, products and services were purchased during the reporting period. 

Comment 


Mediating 

Institution 

Europe 

Consultant 



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- This is a good definition that might be applicable for various supply-chain indicators. 

- Suggestion: include in Glossary 

181 

1520 ASPECT: REMEDIATION CORE G4 7 __Number of grievances __ about environmental impacts filed, addressed, 

Number of grievances 

Comment 


This indicator suggests that a high number of grievances means low compliance with requested standards. This is unfortunately far 

from reality. Zero grievances could for example mean that grievances are surpressed or information channels are limited. In turn, 

high numbers of grievances i.e. from workers directed to supplier management may result from an open and constructive dialogue 

between workers and their representatives. Additionally, grievances issued by campaign organisations are more likely to target wellknown 

companies rather than unknown brands. No. of detected non-compliances (either resulting from a grievance procedure or 

through monitoring procedures) is a far more reasonable measurement. 

181 

1520-1521 __CORE G4 7 Number of grievances about environmental impacts filed, 

add... 

CORE G4 7 Number of grievances about environmental impacts filed, 

addressed, and resolved through formal grievance mechanisms 

Comment 







indicators. 


Business 

Northern 

America 

Reporter 

G4.7, G4.10 and HR11 - Companies are unlikely to have systems to collect data about grievances received in the comprehensive 

manner envisaged here. Tthe distinction between ‘human rights related grievances’ and ‘non-human rights related grievances’ is 

problematic as a concept and extremely difficult to apply in practice. Although some complainants articulate their concerns in the 


Following the suggestion to combine these indicators, this would support a simpler general indicator such as : ‘Number of 

grievances received through formal grievance mechanisms’. 

181 

1520-1521 __Number of grievances about environmental impacts filed, 

addressed, an... 

Number of grievances about environmental impacts filed, 


Mediating 

Institution 

Europe 

Consultant 

Assurance 

Provider 



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Comment 


Applies only to certain industries and should relate to those grievances for the material environmental topics 

181 


• Inte... 


Business 

Northern 

America 

Reporter 




• Membership of underrepresented social groups 

• Other indicators of diversity, if applicable 

Comment 



manner envisaged here. The distinction between ‘human rights related grievances’ and ‘non-human rights related grievances’ is 





181 

1530-1531 of people identified by: • __Membership of underrepresented social groups • Other indicators of diversity, if applicable 

__ Of the identified grievances, report 

Membership of underrepresented social groups • Other indicators of diversity, if applicable 

Replace 


. MEMBERSHIP OF DIVERSITY GROUPS, if applicable 

RATIONALE: 

It should be unified along the GRI G4 guidelines the references to under-represented / underrepresented groups, vulnerable groups, 

indicators of diversity (suggested change to diversity groups), marginalized groups and “Economic Inclusion” (suggested change to 

Social and Economic Inclusion) and the definitions included at glossary level (when used in more than one place). 

181 

1532 indicators of diversity, if applicable __Of the identified grievances, report how many were: __ • Addressed during the 

reporting 


Civil Society 

Organization 

Civil Society 

Organization 

Europe 

Asia 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

Report Reader 

NGO 

concerned 

about certain 



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Insert 


Insert as an additional bullet the following: 

"Filed during the reporting period" 

aspects of 


reporting 

Rationale: 

without this figure, the picture formed will be incomplete as to the number of grievances raised and the number outstanding during 

the reporting period. 

181 

1537 the party that filed the __grievance. __ [Guidance] Relevance Disputes may occur 

grievance. 

Comment 








181 

1547 through formal organizational grievance mechanisms. __Identify __ the total number of grievances 

Identify 

Comment 





181 

1547-1549 __Identify the total number of grievances addressed or resolved during t... 

Identify the total number of grievances addressed or resolved during the reporting period from both 

current year and prior year grievance filings, broken down by the nature and location of the grievance, 

and the party that filed the grievance. 

Comment 


Publishing information publicly regarding parties who formally file grievances could potentially impact confidentiality issues 

between the company and the party filing the grievance 

181 


Business 

Northern 

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Reporter 


Business 

Mediating 

Institution 

Northern 

America 

Europe 

Reporter 

Reporter 

Report Reader 



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Comment 



between the company and the party filing the grievance. 

181 





Comment 




181 





Comment 




181 

1548-1549 __current year and prior year grievance filings, broken down by the natu... 



Comment 




181 

1549 and location of the grievance, __and __ the party that filed the 

and 

Comment 




Business 

Northern 

America 

Reporter 




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181 

1549 and location of the grievance, __and the party that filed the grievance.__ 


Comment 




181 



Comment 




181 



Replace 




181 



Comment 




181 



Comment 





Business 

Northern 

America 

Reporter 



Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 


America 



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181 



Comment 




181 

1549 of the grievance, and the __party that filed the grievance.__ 

party that filed the grievance. 

Comment 




181 

1549 of the grievance, and the __party that filed the grievance.__ 

party that filed the grievance. 

Comment 




215 


CORE G4 8 

Comment 




215 



Comment 








Business 

Northern 

America 

Reporter 


Business 

Northern 

America 

Reporter 



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indicators. 

215 

1563-1564 __Percentage of new suppliers and other business partners screened for l... 

Percentage of new suppliers and other business partners screened for labor practices, and actions taken 

Comment 


Not viable and will lead to significant costs. For local value chains written confirmation for compliance with local laws is enough 

215 

1567-1569 __broken down by the location of the supplier and other business partner... 



Replace 


broken down by the location of the supplier and other business partner AND FORMS OF SOCIAL AND ECONOMIC INCLUSION (SUCH 



. SUPPLIERS INCLUDED AS “FORMS OF SOCIAL AND ECONOMIC INCLUSION”, BROKEN DOWN BY DIVERSITY GROUP 


Civil Society 

Organization 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

RATIONALE: 

The disclosure of forms of social and economic inclusion of suppliers and business partners broken down by diversity and/ or 

vulnerable group (differencing, among others, those social businesses that employ people with disabilities), would provide 

information on percentage of new suppliers and other business partners screened for labor practices that are integrated in other 

‘Forms of Social and Economic Inclusion’. 

215 

1591 partner. Screening for labor practices __may __ cover, but is not limited 

may 

Comment 


should 

215 


may 

Comment 


should 

Civil Society 

Organization 

Civil Society 

Organization 

Northern 

America 

Northern 

America 

Report Reader 

Report Reader 



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215 


may 

Comment 


This needs to be stronger and we suggest the word 'should' is used. 

217 


CORE G4 9 

Comment 




217 


CORE G4 9 

Comment 


Idem G4 6: difficulty of comparability, because there are different methodologies for impact assessment and depending on the 


217 



identified as having actual and potential adverse impacts for labor practices assessed on labor practices, and actions taken 

Comment 







indicators. 

217 


identifi... 



Our members 

help 

organisations 

prepare and 

use 


reports 



Business 

Northern 

America 

Reporter 




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identified as having actual and potential adverse impacts for labor practices assessed on labor practices, and actions taken 

Comment 


Not viable - will lead to competitive disadvantage 

217 

1620 as having actual and potential __adverse impacts __ for labor practices, broken down 


Comment 


- I got the impression that "impact" and "adverse impact" are not used consistently. 

217 

1620-1621 adverse impacts for labor practices, __broken down by the location of the supplier and other 

business partner. __ Report the percentage of total 

broken down by the location of the supplier and other 


Replace 




Mediating 

Institution 

Civil Society 

Organization 

Europe 

Europe 

Consultant 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

RATIONALE: 

The disclosure of the number of suppliers included as “Forms of Social and Economic inclusion” (differenciating, among others, 

those social business that employs people with disabilities), would be an effective tool to assess and monitor actual and / or 

potential adverse impacts for labor practices and actions taken refereed to that particular group. 

217 

1623-1624 adverse impacts for labor practices, __broken down by the location of the supplier and other business partner. __ For 

suppliers and other business 


Replace 




. 

RATIONALE: 

The disclosure of the percentage of forms of social and economic inclusion of suppliers and business partners (differenciating, 

among others, those social businesses that employs people with disabilities), would be an effective tool to assess if / how setting 

expectations on labor practices impacts on a greater engagement with particular forms of social and economic inclusion (such as 

sheltered workshops that employs people with disabilities). 

Civil Society 

Organization 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 



Page 1548 of 2491


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217 




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Comment 






217 


• 

Insert 


FORMS OF SOCIAL AND ECONOMIC INCLUSION (SUCH AS SOCIAL BUSINESSES THAT EMPLOY PEOPLE WITH DISABILITIES) 

RATIONALE: 


business that employs people with disabilities), would be an effective tool to assess the impact of the four reported issues on the 


218 

1659 partner. Assessment of labor practices __may __ cover, but is not limited 

may 

Comment 


Taken as an example, as this occurs in a number of places in the text. The wording ‘may cover’ is not quite strong. A wording such 

as ‘should aim to’ cover would be more forceful while still leaving room for companies explaining some aspects not being applicable. 

220 

1688 CORE G4 10 Number of __grievances __ about labor practices filed, addressed, 

grievances 

Comment 


Civil Society 

Organization 

Civil Society 

Organization 

Europe 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

Report Reader 




Page 1549 of 2491


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220 


CORE G4 10 Number of grievances about labor practices filed, addressed, and resolved through formal grievance mechanisms 

Comment 







indicators. 

Business 

Northern 

America 

Reporter 







220 


Business 

Northern 

America 

Reporter 

• Inte... 





o Gender 




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Comment 








220 



Insert 



RATIONALE: 



Civil Society 

Organization 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 



220 


grievance. 

Comment 








221 

1719-1722 __GRIEVANCE MECHANISMS 

Business 

Business 

Northern 

America 

Northern 

America 

Reporter 

Reporter 

Systems consisting of specified procedures, rol... 

GRIEVANCE MECHANISMS 



Page 1551 of 2491


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Systems consisting of specified procedures, roles and rules for methodically addressing complaints as 

well as resolving disputes. Grievance mechanisms are expected to be legitimate, accessible, predictable, equitable, rightscompatible, 

clear and transparent and based on dialogue and mediation. 

Comment 


The language used to describe Grievance Mechanisms is a bit loose. Suggest the definition should be tighter: ‘A systematic process 

for receiving and responding to grievances’. Also The UN Guiding Principles’ Effectiveness Criteria for grievance mechanisms are 

quoted incorrectly here. The eight principles are: legitimate, accessible, predictable, equitable, transparent, rights compatible, 

based on dialogue and a source of learning. 

221 

1723 based on dialogue and mediation. __SUPPLIER __ See the Glossary for the 

SUPPLIER 

Comment 


The word “significant” has been deleted in reference to the size of the suppliers which need to be tracked. It is unreasonable to 

expect a global organization with thousands of suppliers of various sizes to track these metrics to the degree indicated. 

229 

1770 __significant __ significant significant significant 

significant 

Comment 




229 


significant 

Comment 


The word “significant” hear and below has been deleted in reference to the size of the suppliers which need to be tracked. It is 

unreasonable to expect a global organization with thousands of suppliers of various sizes to track these metrics to the degree 

indicated. 

229 


significant 

Comment 


Business 

Northern 

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Reporter 


Business 

Mediating 

Institution 

Northern 

America 

Europe 

Reporter 

Reporter 

Report Reader 



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229 


significant 

Comment 




229 


significant 

Comment 




229 


significant 

Comment 


comment also for 1789 and 1801: The word “significant” has been deleted in reference to the size of the suppliers which need to be 

tracked. It is unreasonable to expect a global organization with thousands of suppliers of various sizes to track these metrics to the 

degree indicated. 

229 


significant 

Comment 




229 


significant 

Replace 






Business 

Business 

Northern 

America 

Northern 

America 

Reporter 

Reporter 




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229 


significant 

Comment 




229 


significant 

Comment 




229 


significant 

Comment 




229 


significant 

Comment 


Vale suggests that “significant” should not be deleted before “suppliers” due to the larger base of supplies for a global company 

such as Vale. 

229 


significant 

Comment 




229 

1774 significant __significant __ significant significant 

significant 


Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 


America 

Business 

Northern 

America 

Reporter 






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Comment 




229 


significant 

Comment 




229 


significant 

Comment 




229 

1776 significant significant __significant __ significant 

significant 

Comment 




229 


significant 

Comment 




229 


significant 

Comment 


Business 

Business 

Business 

Business 

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Northern 

America 

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Reporter 

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such as Vale. 

229 

1778 significant significant significant __significant__ 

significant 

Comment 




229 


significant 

Comment 




229 


significant 

Comment 



such as Vale. 

231 

1789 __significant__ 

significant 

Comment 




231 


significant 

Comment 




Business 

Business 

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Northern 

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Reporter 


Business 

Mediating 

Institution 

Northern 

America 

Europe 

Reporter 

Reporter 

Report Reader 



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231 


significant 

Comment 




231 


significant 

Comment 




231 


significant 

Comment 




231 


significant 

Replace 




231 


significant 

Comment 




231 


significant 



Business 

Northern 

America 

Reporter 



Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 


America 



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Comment 




231 


significant 

Comment 




231 


significant 

Comment 



such as Vale. 

231 


significant 

Comment 




232 

1792 __SIGNIFICANT SUPPLIERS __ External parties from whom products 

SIGNIFICANT SUPPLIERS 

Comment 




233 


significant 

Comment 


Business 

Northern 

America 

Reporter 



Business 

Business 

Northern 

America 

Northern 

America 

Reporter 

Reporter 



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233 


significant 

Comment 




233 


significant 

Comment 




233 


significant 

Comment 




233 


significant 

Comment 




233 


significant 

Comment 




Mediating 

Institution 

Europe 

Reporter 

Report Reader 




Business 

Northern 

America 

Reporter 



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233 


significant 

Replace 




233 


significant 

Comment 




233 


significant 

Comment 




233 


significant 

Comment 




233 


significant 

Comment 



such as Vale. 

233 


significant 



Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 


America 

Business 

Northern 

America 

Reporter 





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Comment 




234 

1805 __SIGNIFICANT SUPPLIERS __ External parties from whom products 

SIGNIFICANT SUPPLIERS 

Comment 




234 

1812 violations related to human rights. __SUPPLIER __ See the Glossary for the 

SUPPLIER 

Comment 


Under HR 9 and the compilation section with bullet points, there should be more detail on the bullets that relate to Indigenous 

Peoples. Please add: 

*Report on operations where Indigenous communities are affected by activities and where specific engagement strategies are in 

place. 

*Report on evaluation of incident and how avoidance of future incidents will be incorporated into the operations planning and 

implementation. 

238 

1814 __ASPECT: SCREENING AND ASSESSMENT __ CORE HR2 Percentage of new 


Comment 


We believe the definition of Indigenous Peoples should be revised to match that of the GRI Oil and Gas Supplement: 

Indigenous peoples are those whose social, cultural, political, and economic conditions distinguish them from other sections of the 

dominant national community, or who identify (not are regarded) as indigenous on account of their descent from the populations 

which inhabited the country, or a geographical region to which the country belongs, at the time of conquest or colonization or the 

establishment of present state boundaries and who, irrespective of their legal status, retain some or all of their own social, 

economic, cultural, and political institutions. 

We also think it is important to reference other characteristics such as: 

*self-identification as members of a distince indigenous cultural group and recognition of this identity by others, 

Business 

Information 

Users 

Information 

Users 

Northern 

America 

Northern 

America 

Northern 

America 

Reporter 

Report Reader 

Report Reader 



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*collective attachment to geographically distinct habitats or ancestral territories in the project area and to the natural resources in 

thse habitats and territories, 

*Customary cultural, economic, social and political institutions separate from those of the dominant society, 

*An indigenous langugage, often different from the official language of the country or region. 

238 


CORE HR2 Percentage of new suppliers and other business partners screened for human rights performance, and actions 

Comment 


not viable or felt necessary in Indian context where local law compliance can be taken. Will increase costs substantially 

238 

1816 partners screened for human rights __performance, __ and actions taken [Standard Disclosure] 

performance, 

Comment 


This could be Human Rights parameter/ indicators instead of performance. 

238 






Business 

Northern 

America 

Reporter 




Comment 


HR2 Again it is not clear how the break-down will provide insight versus large amounts of data which will be difficult to interpret by 

a reader of the report (rather than an analyst of data). Suggest replacement of 1821/4 with revised 1825 to read “Report material 

issues identified by screening, including nature, locations and actions related to the issue” 

238 

1826-1829 __Report the percentage of new suppliers and other business partners whe... 


screening. 

Business 

Northern 

America 

Reporter 



Comment 



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HR2 These disclosures do not make sense – new suppliers / partners would not be appointed without performance expectations 

following screening, and new suppliers cannot be “not selected” (does it mean proposed suppliers?) 

239 

1848 __• __ Discrimination • Forced and compulsory 

• 

Insert 


• PEOPLE WITH DISABILITY RIGHTS 

RATIONALE: 

The United Nations Convention on the Rights of Persons with Disabilities (2006), ratified so far by the UE and more than 100 

countries individually considers non-discrimination, equal opportunities and social inclusion of people with disabilities a matter of 

human rights and should therefore be taken into account. (http://www.un.org/disabilities/) 

242 


CORE G4 11 

Comment 




242 



identified as having actual and potential adverse human rights 

impacts assessed on human rights performance, and actions taken 

Comment 


Not relevant in Indian context where written confirmation of local laws can be taken. Will increase costs significantly. 

242 



identified as having actual and potential adverse human rights 

impacts assessed on human rights performance, and actions taken 

Comment 




Civil Society 

Organization 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 



Business 

Northern 

America 

Reporter 



Page 1563 of 2491


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indicators. 

243 

1918 limited to: • Child labor __• __ Discrimination • Forced and compulsory 

• 

Insert 


• PEOPLE WITH DISABILITY RIGHTS 

RATIONALE: 

The United Nations Convention on the Rights of Persons with Disabilities (2006), ratified so far by the UE and more than 100 

countries individually considers non-discrimination, equal opportunities and social inclusion of people with disabilities a matter of 

human rights and should therefore be taken into account. (http://www.un.org/disabilities/) 

243 

1935-1936 __performance expectations as a requirement for maintaining a relationsh... 

performance expectations as a requirement for maintaining a relationship with a supplier or other business partner. 

Comment 


We would like to add that these expectations have to be at least in accordance with the organization´s (own) internal expectations 

(mission, vision, value statement) - otherwise the organization is not authentic. 

247 

1983 REMEDIATION CORE HR11 Number of __grievances __ about human rights impacts filed, 

grievances 

Comment 








247 

1983-1984 __CORE HR11 Number of grievances about human rights impacts filed, 

addr... 

CORE HR11 Number of grievances about human rights impacts filed, 


Civil Society 

Organization 

Mediating 

Institution 

Europe 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 

Consultant 

Report Reader 

for academic 

purposes 


Business 

Northern 

America 

Reporter 



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Comment 








247 


• Inte... 





• Gender 

• Membership of underrepresented social groups 

• Other indicators of diversity, if applicable 


• Addressed during the reporting period 

• Resolved during the reporting period 

• Filed prior to the reporting period but resolved during the reporting period 

Comment 


Expanding on the point above, the CORE HR 11 indicator is essentially asking for twelve different pieces of information: 1) 

grievances filed, 2) addressed, 3) resolved; 4) held over from a previous reporting period; a breakdown of complainants by whether 

the complaint is 5) internal, 6) external or 7) a supplier, with further breakdowns by 8) gender, 9) membership of ‘underrepresented’ 

groups, 10) unspecified indicator(s) of ‘diversity’; and all of the above broken down by 11) the topic of the grievance 

and 12) the geographic location of the complainant. 

This level of disclosure is a miniature sustainability report in itself and creates a potentially significant reporting burden on 

companies for relatively little value added in terms of insight into performance. Imposing such a requirement could actually have 

the perverse effect of discouraging operations from using the grievance mechanism in order to avoid dealing with the added 

bureaucracy. This includes attempting to collect detailed information about complainants’ background (‘under-represented social 

groups’ and ‘other indicators of diversity’) could also have perverse consequences in terms of deterring complainants who may have 

Business 

Northern 

America 

Reporter 



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legitimate reasons for not wishing to disclose this information. It is important to bear in mind that in some jurisdictions data 

protection and anti-discrimination laws may impose restrictions on gathering this kind of data in the first place. The result might be 

fewer grievances being handled overall – hardly a satisfactory outcome. 

It should also be noted that for commercial and legal reasons, reporting on grievances received from suppliers is problematic. In 

addition, the indicator is not clear about reporting boundaries: is a company expected to report only on non-commercial grievances, 

or on all grievances? 







247 

1995 of underrepresented social groups • __Other indicators of diversity, if applicable __ Of the identified grievances, report 


Replace 


OTHER DIVERSITY GROUPS (e.g.PEOPLE WITH DISABILITIES) 

RATIONALE: 



Civil Society 

Organization 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 


reports 



247 

2000 of the grievance, and the __party __ that filed the grievance. [Guidance] 

party 

Comment 


Publishing specific information regarding parties who formally file grievances could potentially impact confidentiality issues 


247 

2000 resolved during the reporting period __Break __ down the above disclosure by 

Break 

Comment 

Business 

Northern 

America 

Reporter 




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247 

2000 resolved during the reporting period __Break __ down the above disclosure by 

Break 

Comment 





247 



Comment 




247 



Comment 




247 



Comment 




247 



Comment 



Business 

Mediating 

Institution 

Northern 

America 

Europe 

Reporter 

Reporter 

Report Reader 





Page 1567 of 2491


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247 



Comment 




247 



Comment 




247 



Comment 




247 



Replace 




247 



Comment 




Business 

Northern 

America 

Reporter 


Business 

Northern 

America 

Reporter 



Gold Mining 

Company that 

reports in 

accordance 

with the GRI 

Guideline 



Page 1568 of 2491


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247 



Comment 




247 



Comment 




247 


grievance. 

Comment 








268 


CORE G4 12 

Comment 




268 



Comment 


Business 

Northern 

America 

Reporter 


Business 

Northern 

America 

Reporter 


Civil Society 

Organization 

Europe 

Report Reader 

Database of 

corporate 

responses to 

climate 

change, water 



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thinking of the type of question that we at CDP get asked by companies, is there a definition of “society-related” encompasses to 

improve comparability of answers? Would it be linked to the topics within “Society” category? 

268 

2028-2029 __G4 12 Percentage of new suppliers and other business partners screened... 

G4 12 Percentage of new suppliers and other business partners screened for society-related performance, and actions taken 

Comment 


Will this also require a formal assessment. Will create lot of consultation opportunities which may not be the intent of this guideline 

268 

2029 and other business partners screened __for society-related performance, __ and actions taken [Standard Disclosure] 

for society-related performance, 

Comment 


This indicator is very very unconcrete. What do you mean by "society-related performances"? It would help a lot, if you could give 

some examples. 

268 

2029 other business partners screened for __society-related performance, __ and actions taken [Standard Disclosure] 

society-related performance, 

Comment 


"Society-related performance" needs definition and clarity. 

270 


CORE G4 13 

Comment 




270 


CORE G4 13 

Comment 




270 


identifi... 

and forestryrelated 

issues 


Mediating 

Institution 

Business 

Europe 

Northern 

America 

Consultant 

Report Reader 

for academic 

purposes 

Reporter 






Page 1570 of 2491


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identified as having actual and potential adverse impacts on 

society assessed on society-related performance, and actions 

taken 

Comment 


Not feasible or do able 

270 

2074 impacts on society assessed on __society-related performance, __ and actions taken [Standard Disclosure] 


Comment 


"Society-related performance" needs definition. 

270 




Business 

Business 

Northern 

America 

Northern 

America 

Reporter 

Reporter 




Comment 






271 

2131-2133 __For the purpose of this Indicator, a specific term in a written agreem... 

For the purpose of this Indicator, a specific term in a written agreement that defines minimum 

performance expectations as a requirement for maintaining a relationship with a supplier or other 


Comment 


We would appreciate if you could add that these expectations have to be also fulfilled by the reporting organization (vision, mission, 

value statement) - otherwise the organization is not authentic. 

Mediating 

Institution 

Europe 

Consultant 

Report Reader 

for academic 

purposes 



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272 

2141 ASPECT: REMEDIATION __CORE G4 14 __ Number of grievances about society-related 

CORE G4 14 

Comment 




272 

2141 CORE G4 14 Number of __grievances __ about society-related impacts filed, addressed, 

grievances 

Comment 








272 

2145 grievance mechanisms [Standard Disclosure] Compilation __Report __ the total number of grievances 

Report 

Comment 


It is unclear what has been gained by replacing, “Material topics for a reporting organization should include those topics that have a 

direct or indirect impact on an organization’s ability to create, preserve or erode economic, environmental and social value for itself, 

its stakeholders and society at large.” with, “An reporting organization should identify material topics related to all of its activities, 

products, services, and relationships. Material topics should include those topics that: 

• reflect the organization’s significant economic, environmental, and social impacts, or that 

• substantively influence the assessments and decisions of stakeholders” 




Absent a definition of ‘significant’, the original text was much clearer. 

272 



Replace 


OTHER DIVERSITY GROUPS (e.g. PEOPLE WITH DISABILITIES) 

Civil Society 

Organization 

Europe 

Report Reader 

Work to 

promote and 

enhance the 

disability 

disclosure in 



Page 1572 of 2491


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RATIONALE: 




reports 



314 

2681 management teams are senior executives. __SUPPLIER __ An organization or person that 

SUPPLIER 

Comment 


- In some indicators the term "business partner" is used. What is the difference between supplier and business partner? The list 

under supplier seems already very compelling. 

314 

2682 provides materials, products or services __directly or indirectly __ to another organization. In GRI’s 

directly or indirectly 

Comment 


Due to major differences in Management Approaches towards first and second tier suppliers a clear definition and distinction 

between both is clearly needed. 

315 

2684 • Brokers: __Persons __ or organizations that buy and 

Persons 

Comment 


Individuals 

315 

2686 that supply labor. • Consultants: __Persons __ or organizations that provide expert 

Persons 

Comment 


Individuals 

315 

2689 as employees of another organization. __• __ Contractors: Persons or organizations working 

• 

Comment 


TWO-TIER BOARD should be defined 

Mediating 

Institution 

Europe 

Consultant 


Information 

Users 

Information 

Users 

Europe 

Europe 

Report Reader 

Report Reader 




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315 

2689 of another organization. • Contractors: __Persons __ or organizations working onsite or 

Persons 

Comment 


Individuals 

315 

2700 relationship with the organization. • __Primary producers: Persons or organizations that grow, harvest, or extract raw 

materials. __ • Wholesalers: Sellers of goods 

Primary producers: Persons or organizations that grow, harvest, or extract raw materials. 

Comment 


Why is ‘producers’ limited to ‘primary producers’? Other producers are not mentioned in the list, even though producers of nonprimary 

products may be a very significant part of many supply chains. 

315 

2707-2708 __The part of the value chain which consists of the sequence of supplier... 

The part of the value chain which consists of the sequence of suppliers and activities that provides 

materials, products or services to an organization. 

Comment 


Unclear if this includes only 1st tier or more. 

Information 

Users 

Civil Society 

Organization 

Europe 

Northern 

America 

Report Reader 

Consultant 

GHG reporting 

standards 

developer 




Page 1574 of 2491



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26 

82 impacts of the organization. This __includes __ impacts it causes, contributes to, 

includes 

Comment 


may include 

26 

82 key challenges associated with __performance impacts __ of the organization. This includes 

performance impacts 

Comment 


"performance" is more neutral. Or "impacts" may need to be expanded to "impacts and dependencies" (on eg nature), the 

formulation used in TEEB research. "Dependencies" is about impact on the reporting organisation, which (along with impact on 

stakeholders) is key in the materiality exercise. 

26 


impacts 

Comment 


I think that guidance provided to support the Disclosures on Management Approach is complete for this moment, but I 

suggest for the board observed the discussions elaborated for International Federations on Accountants about Audit and Risk 

analysis, these considerations are very important for analysis of reporting, integrated reporting and XBRL. 

1-https://www.ifac.org/publications-resources/improving-auditor-s-report 

2-https://www.ifac.org/publications-resources/investor-demand-environmental-social-and-governance-disclosures 

3- https://www.ifac.org/publications-resources/competent-and-versatile-how-professional-accountants-business-drive-sustainab 

4- http://www.theiirc.org/wp-content/uploads/Yearbook_2012/sources/indexPop.htm 

26 


impacts 

Comment 

Mediating 

Institution 

Mediating 

Institution 

Mediating 

Institution 

Mediating 

Institution 

Oceania 

Europe 

Latin America 

Oceania 

Report Reader 

STUDENT 

GROUP 

ASSIAGNMENT 

FOR 

MACQUARIE 

UNIVERSITY 

AUSTRALIA 

ACCG 260 

GROUP 

Consultant 

Report Reader 

Reporter 

Report Reader 

STUDENT 

GROUP 

ASSIAGNMENT 

FOR 



Page 1575 of 2491


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significant imoacts 

26 


impacts 

Comment 


Generally speaking the word "impact" has a negative connotation, especially in the sustainability space. If GRI truely means that an 

impact can be positive or negative, it may want to consider a different word, such as "effect." 

26 

83 a result of relationships with __others __ (e.g., suppliers, people or organizations 

others 

Replace 


its stakeholders. Delete the sentence in bracket too. 

Context in line with the definition of stakeholder in the text. 

26 

83-84 result of relationships with others __(e.g., suppliers, people or organizations in local communities).__ 

(e.g., suppliers, people or organizations in local communities). 

Comment 


delete the highlighted line and insert " its stakeholder" 

Rational/ context it gives a better clarity and also in line with the stakeholder engagement process described earlier in the text. 

27 




Comment 

Mediating 

Institution 

Northern 

America 

MACQUARIE 

UNIVERSITY 

AUSTRALIA 

ACCG 260 

GROUP 

Consultant 


Assurance 

Provider 

Report Reader 

Assurer 


std., ISO-14064 


ISO-14001 

Lead auditor 


Assurance 

Provider 

Report Reader 

Assurer 


std., ISO-14064 


ISO-14001 

Lead auditor 


Report Reader 



Page 1576 of 2491


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It may be confused with DI 7 and 9 

27 




Comment 



27 




Comment 



28 

90 or __or __ supply chain and and 3. 

or 

Insert 


insert "management control" 

Context- in many cases of acquisition management control is given but not the ownership. This change is also in line with the 

organization boundary definition 

28 


or 

Comment 


any significant changes occuring during the organisation reporting period 

28 





Assurance 

Provider 

Report Reader 

Assurer 


std., ISO-14064 


ISO-14001 

Lead auditor 

Mediating 

Institution 

Financial 

Markets & 

Oceania 

Europe 

Report Reader 

STUDENT 

GROUP 

ASSIAGNMENT 

FOR 

MACQUARIE 

UNIVERSITY 

AUSTRALIA 

ACCG 260 

GROUP 

Report Reader 



Page 1577 of 2491


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or 

Comment 


In the view of Sustainalytics, the GRI4 framework must include mandatory disclosure of companies' exposure to geographic specific 

ESG risks. 

Mandatory disclosure on the above aspects will help external and internal stakeholders to obtain an improved understanding of 

companies direct risk exposure, in terms of operational, physical, financial, reputational and regulatory aspects. Currently only a 

limited number of companies globally disclose relevant and structured information on the exact location and scale of operations. 

Often environmental and social risks for companies are characterised by being highly specific and local in terms of geographical 

conditions, for instance, water scarcity and biodiversity hotspots. These characteristics require company reporting on operations 

and their scale in order to assess the actual environmental and social impacts. 

Financial 

Markets & 

Information 

Users 

In the view of Sustainalytics, the proposed GRI 4 reporting framework could put more emphasis on mandatory disclosure of 

countries of operation, by making use of materiality matrix and significance identification in terms of the revenue proportions, 

impacts by products and services, or the number of workers in the payroll. 

28 



Report Reader 




termination 

Comment 


It shall be specified when such events must be reported, considering that the supplyn chain for some companies are big and often 

suffer changes, what makes its report very complex and difficult. 

28 






termination 

Comment 



Page 1578 of 2491


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suffer changes, what makes its report very complex and difficult. 

28 

93-97 __and and 

3. The location of suppliers, or changes in relationships wi... 

and and 



termination 

Comment 



suffer changes, what makes its report very complex and difficult 

28 

96 and 3. The location of __suppliers, __ or changes in relationships with 

suppliers, 

Comment 


significant 


Big corporations could easily achive thousands of suppliers worldwide 

28 



termination 

Comment 


This is not practical to report - for me to inventory all changes in relationships with suppliers I believe is an unreasonable amount of 

work (this is not a dynamic that is tracked centrally), and I think is an academic discussion that doesn't really provide useful 

information to stakeholders. 

28 


termination 

Comment 


and certain reasons may be required to be presented. 

Business 

Mediating 

Institution 

Northern 

America 

Oceania 

Reporter 

Report Reader 

STUDENT 

GROUP 

ASSIAGNMENT 

FOR 

MACQUARIE 



Page 1579 of 2491


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29 


Describe the organization’s supply chain. __ [Guidance] A description of the 



Comment 


"The total number of suppliers" is virtually impossible to be reported by large companies. It's a very dynamic data that changes 

every moment. 

It's not clear if it is expected for "the total number of suppliers" the data in December 31st or all suppliers during the reported 

period. 

UNIVERSITY 

AUSTRALIA 

ACCG 260 

GROUP 


Report Reader 

The text may be "The total number of suppliers or significant suppliers". 

29 






Comment 



every moment. 


period. 


29 





Page 1580 of 2491


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Comment 



every moment. 


period. 


29 

99 [Disclosure] DI 12 __Describe the organization’s supply chain. __ [Guidance] A description of the 


Comment 


Great idea 

29 

101 but is not limited to: __1. Total number of suppliers __ 2. Total monetary value and/or 


Comment 


Broken down to size categories : Small, Medium, Large. 

This will give a clearer picture and will enable companies to choose in the following indicators where to elaborate. 

29 



Comment 


Line 101: 

Breakdown of the supply chain is limited to expenditure only. ¿Would it make sense to extend this breakdown to the number of 

suppliers also? 

29 



Mediating 

Institution 

Northern 

America 

Consultant 


Academic 


Business 

Northern 

America 

Reporter 



Page 1581 of 2491


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Comment 


This is not something that a multi-national would be able to provide easily. This would take a considerable amount of work. 

29 



Comment 


Even for a small company that data is difficult and very time intensive to collect 

29 



Comment 


Even total number of suppliers is not a straigh-forward question - is this number of different payees in our accounting system (which 

may include multiple accounts for the same supplier company), and since we pay suppliers from different business locations I would 

need to reconcile for duplicates from each accounts payable unit. 

29 

102 materials, products and services purchased __directly __ from suppliers, broken down by: 

directly 

Comment 


Does this imply an exemption if you use agents? If so I would erase 'direct'. 

29 










Comment 


For a multi-national organization this is not something that can easily be done. What I would like to understand is waht this has to 

do with CSR and Sustainability. GRI is meant to create consistency in CSR reporting, but this is not clearly outlined here - no 

understanding on what would make this material to an organization. 

Mediating 

Institution 

Business 

Europe 

Northern 

America 

Consultant 

Training 

Partner 

Reporter 


Business 

Northern 

America 

Reporter 



Page 1582 of 2491


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29 










Comment 


Again, surely we can focus this on some cut-off assessment of larger suppliers ? 

29 

103 and services purchased directly from __suppliers, __ broken down by: a. The 

suppliers, 

Comment 


Suggest to ad main suppliers or substantial supplier. Include a seperate note asking for reporting/definition by the organisation 

what they understand by main og large. To report this for all suppliers may not be feasible, and will only be true the scond you send 

the report. The minute after the number, type and location will have changed for many... 

29 

104 suppliers, broken down by: a. __The types of materials, products and services __ provided by suppliers that are 

The types of materials, products and services 

Comment 


Might be considered as business secrets so company will not disclose such info 

29 


suppliers 

Comment 


Perhaps indicate the levle of participation of the local suppliers vs. external suppliers. 

29 

106 as reported under DI 4 __b. Types of suppliers __ c. Location of suppliers by 


Comment 

Business 

Northern 

America 

Reporter 


Mediating 

Institution 

Mediating 

Institution 

Mediating 

Institution 

Asia 

Northern 

America 

Oceania 

Consultant 

Reporter 

Consultant 

Assurance 

Provider 

Report Reader 

Report Reader 

STUDENT 

GROUP 

ASSIAGNMENT 

FOR 



Page 1583 of 2491


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b. supliers type or suppliers nature or supplier organisation nature & background 

29 



Comment 


Line 106: 

Seems reasonable to be more accurate on this topic. Maybe a specific section on the glossary to indicate what this statement 

attempts to mean would be the right choice. 

For example, we could differentiate supplier type by: 

1.- Depending on the destination of supplies we could differentiate between "direct" (supplies that contribute to the organization 

standardized product/services)or "indirect" (other generic supplies that do not contribute to the standard product/service)supplies 

2.- "Critical suppliers" as those high volume suppliers, critical component suppliers & non-substitutable suppliers vs "Non Critical". 

3.- "Tier 1 suppliers" when refering to vendors that are directly supplying goods or services to the organization (in contrast to tier2 

suppliers, who are supplying to the tier 1 supplier etc.). 

MACQUARIE 

UNIVERSITY 

AUSTRALIA 

ACCG 260 

GROUP 


I didn´t found any guidance in the document providing assitance on this issue. 

29 

107 suppliers by country and/or region. __Where __ it will provide appropriate context 

Where 

Comment 


where and why 

29 





Mediating 

Institution 

Mediating 

Institution 

Oceania 

Northern 

America 

Report Reader 

STUDENT 

GROUP 

ASSIAGNMENT 

FOR 

MACQUARIE 

UNIVERSITY 

AUSTRALIA 

ACCG 260 

GROUP 

Assurance 

Provider 



Page 1584 of 2491


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Comment 


This will be difficult for large companies with tens of thousands of suppliers. Consider limitiing this to significant suppliers. 

29 

108 will provide appropriate context on __relevant __ risks and impacts, identify the 

relevant 

Comment 


For the same principal objective of disclosure I think, I do not have certain that for supplay chain need to observed the same 

discussions elaborated for IFAC and principally https://www.ifac.org/publications-resources/competent-and-versatilehowprofessionalaccountants-business-drive-sustainab 

29 

112 Glossary for the definitions of __supply __ chain and supplier. References • 

supply 

Insert 


The definition of supply chainto be changed as under 

"Supply chain referes to a network of organizations (e.g. manufacturers, wholesalers, distributors and retailers) involved in 

production, delivery and sale of a product to consumer." 

Context/ rational: The more precise definition is given by WRI/WBCSD. Reference GHG protocol supplement (2011) 

30 

128 in the value chain. supplier __satisfaction __ surveys, 

satisfaction 

Comment 


good sugestions 

30 

128 the value chain. supplier satisfaction __surveys,__ 

surveys, 

Comment 


Consider the use of tables in this section. Include data on the number of internal and external stakeholders who participated in the 

consultation. Categorize the participants (use categories such as Inform, Consult, and Actively participate) Include a breife profile of 

the particpants. 

Mediating 

Institution 

Latin America 

Reporter 


Assurance 

Provider 

Report Reader 

Assurer 


std., ISO-14064 


ISO-14001 

Lead auditor 


Institution 

Mediating 

Institution 

Northern 

America 

Reporter 

Consultant 

Assurance 

Provider 

Report Reader 



Page 1585 of 2491


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30 

128 topics) in the value chain. __supplier __ satisfaction surveys, 

supplier 

Comment 


Line 128: 

"customer, employee ans supplier satisfaction surveys", specific communication mailboxes, roadshows with investors.... 

30 



Comment 


DOes this refer to the suppliers satisfaction with the reporter or to some other audience's satisfaction with the supllier. It would be 

good to be more specific. 

31 



Comment 


Is the expectation here to name the actual group (e.g. the name of a specific NGO) or just the type of group? 

31 


group, 

Comment 


See my previous comment. Conside the use of same categories here too and think of the levle of participation: Inform, Consult, or 

actively participate. 

48 



Comment 


Complex considering a broad supply chain. Better to focus on critical suppliers. 

48 



Comment 


Mediating 

Institution 

Mediating 

Institution 

Mediating 

Institution 

Northern 

America 

Northern 

America 

Northern 

America 

Consultant 

Consultant 

Reporter 

Consultant 

Assurance 

Provider 

Report Reader 


Report Reader 




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48 

638 standards, protocols, and policy agendas. __• Procurement Practices __ [Disclosure] Report policies and practices 

• Procurement Practices 

Comment 



49 

653 are not limited to: • __Suppliers owned by women __ • Suppliers owned or staffed 

Suppliers owned by women 

Comment 


Line 653: 

Seems extremely difficult to detect the gender ownership of the supplier. In practice is impossible to determine when dealing with 

big suppliers. 

On the other hand, in some developing countries this figure will never be relevant nor reflect the sustainability efforts of a 

responsible company. 

53 

673 ASPECT: __PROCUREMENT PRACTICES __ CORE EC6 Spending on locally-owned 

PROCUREMENT PRACTICES 

Comment 


What is considered good enough for "in accordance with" GRI on supply chain management? Text could be clearer on what GRI 

accepts e.g. top 50 suppliers or strategic suppliers, or by volume 

53 


EC6 

Comment 


This is an indicator that could be added to the management disclosure. How companies improve local development by working with 

local suppliers. 

53 


locally-owned 

Comment 


"Locally owned" is not clear. Local to what? Our company has a national footprint and we have over 5,000 suppliers accounting for 



Mediating 

Institution 

Europe 

Consultant 

Assurance 

Provider 

Report Reader 


Business 

Northern 

America 

Reporter 



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our sourceable spend. We purchase finished goods, which may be manufactured in another country, so we feel that locality is not 

material for reporting. Additionally, large tranches of spend are associated with software. Again, "local" in this context is vague and 

immaterial. 

53 



Insert 


Section on Base of Pyramid initiatives. This would be important for stakeholders to understand clearly the investment into 

communities, whilst also the innovation of new products for specific locations. 

53 

675 forms of economic inclusion, at __significant __ locations of operation [Standard Disclosure] 

significant 

Comment 


major 

53 

678 operation. Provide information on how __locally-owned __ suppliers and significant locations of 

locally-owned 

Comment 


I prefer the term locally-based as in G3.1 rather than locally-owned. That would be very difficult indeed for organizations to find out 

if their suppliers are locally owned because the term is very vague. 

53 

678-679 information on how locally-owned suppliers __and significant locations of operations were defined. __ Report the 

percentage of total 

and significant locations of operations were defined. 

Comment 


I believe its the question of boundry not of an indicator protocol. 

53 

679 significant locations of operations were __defined. __ Report the percentage of total 

defined. 

Comment 

Mediating 

Institution 

Mediating 

Institution 

Mediating 

Institution 

Mediating 

Institution 

Mediating 

Institution 

Europe 

Oceania 

Asia 

Asia 

Oceania 

Consultant 

Assurance 

Provider 

Report Reader 

STUDENT 

GROUP 

ASSIAGNMENT 

FOR 

MACQUARIE 

UNIVERSITY 

AUSTRALIA 

ACCG 260 

GROUP 

Consultant 

Report Reader 

GRI Regional 

Data 

Partnership 

Consultant 

Report Reader 

GRI Regional 

Data 

Partnership 

Report Reader 

STUDENT 

GROUP 

ASSIAGNMENT 



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and please list the brief reason 

53 

680 spending on locally-owned suppliers at __significant __ locations of operation. Report the 

significant 

Comment 


major 

53 

681 suppliers at significant locations of __operation. __ Report the percentage of total 

operation. 

Comment 


and please list the brief reasons 

53 

682 spending on locally-owned suppliers at __significant __ locations of operation broken down 

significant 

Comment 


major 

53 

684 for ‘other forms of economic __inclusion’. __ CORE G4 1 Spending on 

Mediating 

Institution 

Mediating 

Institution 

Mediating 

Institution 

Mediating 

Institution 

Oceania 

Oceania 

Oceania 

Oceania 

FOR 

MACQUARIE 

UNIVERSITY 

AUSTRALIA 

ACCG 260 

GROUP 

Report Reader 

STUDENT 

GROUP 

ASSIAGNMENT 

FOR 

MACQUARIE 

UNIVERSITY 

AUSTRALIA 

ACCG 260 

GROUP 

Report Reader 

STUDENT 

GROUP 

ASSIAGNMENT 

FOR 

MACQUARIE 

UNIVERSITY 

AUSTRALIA 

ACCG 260 

GROUP 

Report Reader 

STUDENT 

GROUP 

ASSIAGNMENT 

FOR 

MACQUARIE 

UNIVERSITY 

AUSTRALIA 

ACCG 260 

GROUP 

Report Reader 

STUDENT 



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inclusion’. 

Comment 


and list the brief reasons. 

53 

685-693 __CORE G4 1 Spending on suppliers with which long-term agreements exist ... 





CORE G4 2 Percentage of suppliers with which orders were placed for the first time during the 

reporting period 


Mediating 

Institution 

Northern 

America 

GROUP 

ASSIAGNMENT 

FOR 

MACQUARIE 

UNIVERSITY 

AUSTRALIA 

ACCG 260 

GROUP 

Consultant 

Report the percentage of total suppliers with which orders were placed for the first time during the reporting period. 

Comment 


Unsure of the relevance of these two new indicators. 

53 

687 spent on suppliers with which __long-term __ agreements exist. CORE G4 2 

long-term 

Comment 


Organisations must be encouraged what for them is a realistic 'long term' view in supply chain engagement. Is long term useful ? 

The statement/disclosure assumes long term is better. We dont know. In order to drive improvemnts, sometimes a mixed approach 

may work. 

53 

689 agreements exist. CORE G4 2 __Percentage __ of suppliers with which orders 

Percentage 

Comment 





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Does this indicator really adds value? What are looking at here? If organizations are changing suppliers every year or benefiting 

some for a long period? 

53 


CORE G4 2 

Comment 


Is this really relevant and reasonable to ask as a CORE indicator? There can be too many factors involved that result in high turnover 

of suppliers. Consider making it ADDITIONAL. 

53 

689-690 Percentage of suppliers with which __orders were placed for the first time during the reporting period __ [Standard 

Disclosure] Report the percentage 

orders were placed for the first time during the reporting period 

Comment 


What is the rationale for asking this disclosure? Companies responding would like to know- and how doe this related to other supply 

chain indicators. 

53 



Comment 


For large companies with extensive supply chain, it´s better to specify what kind of purchase need to be reported. In this case we 

suggest only to consider the critical itens for operations and processes. 

53 



Comment 




53 



Comment 


Mediating 

Institution 

Europe 

Consultant 

Assurance 

Provider 

Report Reader 



Report Reader 





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53 



Insert 


Report value of orders to new suppliers to demonstrate economic impact and context to spend for the operations by location 

54 



Comment 


Would be misguiding in various cases and become useless 

54 


G4 

Comment 


This should also be considered as a management disclosure indicator. 

54 

694-697 __CORE G4 3 Time taken to pay suppliers 


Report... 



Report the average number of days taken to pay supplier invoices. 


Comment 


Excellent addition. Large companies oftentake advantage of the cash flow and interest opportunities afforded by delaying payments 

to smaller companies to the point where it affects the economic sustainability of the smaller companies, , especially in these times 

where smaller companies are finding it harder to access operating capital. 

Mediating 

Institution 

Mediating 

Institution 

Europe 

Asia 

Consultant 

Assurance 

Provider 

Consultant 

Report Reader 

GRI Regional 

Data 

Partnership 


Mediating 

Institution 

Northern 

America 

Consultant 



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54 

696 to pay suppliers [Standard Disclosure] __Report the average number of days taken to pay supplier invoices. __ Report the 

percentage of total 


Comment 


This question refers to what kind of performance? less days are better? 

In most commercial law families, legal entities are free to conclude any term (including payment timelines). How can a timeline of 

payment on which 2 parties are agreed, indicate a - or + performance? 

54 

696-697 __Report the average number of days taken to pay supplier invoices. 

Re... 


Mediating 

Institution 

Business 

Asia 

Northern 

America 

Consultant 

Report Reader 

GRI Regional 

Data 

Partnership 

Reporter 


Comment 


This is something that would be incredibly difficult to report on in an organization that spans over 55 countries. It seems like the 

level of impact of this question does not equal the amount of work it would take to collect and report on this information. 

54 

697 invoices. Report the percentage of __total payments __ to suppliers that were made 

total payments 

Comment 


"Total payments" is not clear. Does this mean number of invoices? Number of transactions? Amount of money? We will bundle 

several invoices into a single payment to reduce administration cost. Also suggest including the word "undisputed" because there 

may be an invoice that we dispute and which may result in a protracted resolution discussion. 

54 

697 taken to pay supplier invoices. __Report the percentage of total payments to suppliers that were made late. __ ADD G4 4 

Percentage of 


Insert 


Report the standard terms for payment. If they differ across geographies, report why and what the differences are.Report on 

average how late payments are. Late payments can be of serious concern to suppliers and create a significant negative economic 

impact. Explain in general why payments are late: is it poor communication, poor invoicing or poor supplier management for 

example. 

Business 

Mediating 

Institution 

Northern 

America 

Europe 

Reporter 

Consultant 

Assurance 

Provider 



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54 

697 to suppliers that were made __late. __ ADD G4 4 Percentage of 

late. 

Comment 


I find it very "1st world corporate" Does not cover SME practices or for any size in some geogrphies in terms of trading culture. For 

example in Turkey, long term bearer cheques are commonly used in SMEs. In legal terms it like cash payment, however waiting for 

the term is a custom. Is it payment on time or not? Furthermore, imagine that those cheques are made over to others multiple 

times. In that terms indicator becomes impossible to get over with. 

54 

698 made late. ADD G4 4 __Percentage __ of monetary value of each 

Percentage 

Comment 


Since most of the products ans services do not have a certification (there has been an increase in certifications, but a lot still is not 

under this type of criteria) what really is this indicator adding value? Or showing that my company is more sustainable engaged? 

And for most of the organizations this percentage will be very insignificant, while for others where certification has evolved, will 

represent much more. 

54 

698-699 Percentage of monetary value of __each type of materials, products and services 

purchased __ that have been verified or 

each type of materials, products and services 

purchased 

Comment 


This disclosure needs some type of context around it - whether that be materials products and services that have been identified as 

coming from sensitive sources or just those that the company buys a lot of. 

54 





Comment 


Complex considering a broad supply chain. Better to focus on critical itens. 

54 



Mediating 

Institution 

Asia 

Consultant 

Report Reader 

GRI Regional 

Data 

Partnership 


Mediating 

Institution 

Northern 

America 

Consultant 


Report Reader 




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Comment 



54 





Comment 



54 





Comment 


The wording of this reporting requirement is too broad to result in a cogent response. "Widely-recognized" by whom? We purchase 

a large amount of software and software maintenance services and we contractually require our suppliers to comply with local laws. 

But, we do not require them to certify that commitment. We feel that the question should be reworded so that the context is 

reporting on the materials, products, etc. that are material to our company, not the entire supply chain. 

56 

733 • Screening and Assessment • __Remediation __ [Disclosure] Report the availability and 

Remediation 

Comment 


Remove the confusion of word remediation- as in environment remediation is more commonly used for the removal of 

contamination/pollutants e.g. oil spill remediation. 

56 

735-739 __Report the availability and accessibility of grievance mechanisms and ... 




Business 

Northern 

America 

Reporter 


Assurance 

Provider 

Report Reader 

Assurer 


std., ISO-14064 


ISO-14001 

Lead auditor 


America 



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Comment 


As we purchase finished goods, whose components might be manufactured by multiple companies, we do not have manufacturing 

contracts. We have no privity to our suppliers' contracts and have no way of evaluating the availability and accessibility of grievance 

mechanisms, as well as the level of involvement by third party monitoring agents. If a supplier has been audited and certified by a 

third party, the provision should be modified to identify the certification type, source, and effective time period. Again, we think it 

makes sense to focus on those suppliers that are material or we consider critical. 

56 

736 and the involvement of local __community/workers’ __ representatives’ in monitoring their effectiveness. 

community/workers’ 

Comment 


I think that is very important observed in UNTACD about indicators in the others cultures, is very important observed some points of 

transparency international too. http://www.transparency.org/ 

56 

738 representatives’ in monitoring their effectiveness. __Report the types of training __ on the availability and accessibility 

Report the types of training 

Comment 


Training to whom? 

56 



Comment 


In this case it shall be clearly pointed if it refers to workforce or if it also includes communities and other stakeholders 

56 



Comment 



56 



Comment 

Mediating 

Institution 

Mediating 

Institution 

Latin America 

Northern 

America 

Reporter 

Consultant 


Report Reader 





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64 

745 partners screened for environmental performance, __broken down by the location of the supplier __ and other business 

partner. Break 

broken down by the location of the supplier 

Comment 


What is the intent/rationale here? Assume we are interested in 'Local' and not 'Location'...if it is the later, this may potentially run 

into pages... 

64 

746 down the following four disclosures __by: __ • The location of the 

by: 

Comment 


and describe the major reasons in brief. 

64 

750 business partner) Report issues identified __through screening. __ Report the percentage of new 

through screening. 

Comment 


delete 

64 




Comment 


Unsure why the percentage of suppliers not selected is important. Perhaps a brief description of why suppliers werre rejected would 

be useful. But why a percentage? How does one measure performance improvement in this area? Higher or lower % of rejection? 


Mediating 

Institution 

Mediating 

Institution 

Mediating 

Institution 

Oceania 

Oceania 

Northern 

America 

Report Reader 

STUDENT 

GROUP 

ASSIAGNMENT 

FOR 

MACQUARIE 

UNIVERSITY 

AUSTRALIA 

ACCG 260 

GROUP 

Report Reader 

STUDENT 

GROUP 

ASSIAGNMENT 

FOR 

MACQUARIE 

UNIVERSITY 

AUSTRALIA 

ACCG 260 

GROUP 

Consultant 



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64 

755 result of screening. Report other __actions __ taken to address the issues 

actions 

Comment 


new and innovative actions 

64 

744 and actions taken [Standard Disclosure] __Report __ the percentage of new suppliers 

Report 

Comment 


G4 5 asks for three different percentage values to be calculated on lines 744, 751 and 753. As such, there seems to be multiple 

disclosure requirements combined into one indicator, whereas it is best practice to ensure that an indicator only measures a single 

data point. Hence this indicator need to be split up into separate indicators or else the indicator wording needs to be revised, and 

the indicator protocol developed for clarity. 

64 

744 suppliers and other business partners __screened __ for environmental performance, broken down 

screened 

Comment 



64 

744-745 suppliers and other business partners __screened for environmental 

performance, __ broken down by the location 

screened for environmental 

performance, 

Comment 


I'm not sure how other service companies do this. In our vision there has to be a balance between people, planet and profit aspects. 

64 

748 and other business partner • __The nature of the issue __ • The location of the 

The nature of the issue 

Comment 


748 Clarification needed - What does ‘nature of the issue’ refer to? 

64 

750 supplier and other business partner) __Report __ issues identified through screening. Report 

Report 

Mediating 

Institution 

Mediating 

Institution 

Europe 

Asia 

Consultant 

Consultant 

Assurance 

Provider 



Mediating 

Institution 

Mediating 

Institution 

Oceania 

Oceania 

Reporter 

Consultant 

Assurance 

Provider 

Report Reader 

Reporter 

Consultant 

Assurance 



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Comment 


750 Report issues identified through screening – talks about reporting on issues) 

Suggested addition: “Break down the following four disclosures by”… supplier self-assessment/independent audit 

64 

750 supplier and other business partner) __Report issues identified through screening. __ Report the percentage of new 


Comment 


These will have business confidentiality implications. Competitors can make use of such disclosures to create vulnerabilities 

64 




Comment 


Reporting on environmental screening seems to have a high focus on issues identified and adverse impacts. This should stay in the 

guidelines. But possibly it is good to include room where companies can disclose continues choices made for suppliers to establish 

positive impacts. Environmental screenings can also have a positive incentive in them, not only focusing in not buying or investing in 

pollution, but pro-actively supporting green businesses. 

Provider 

Report Reader 


Civil Society 

Organization 

Europe 

Report Reader 

In general this feedback goes for all assessment and screening indicators also on labour practices, human rights, and society-based 

aspects. 

67 

817 to receive by national labor __law. __ Report actions taken to address 

law. 

Comment 


,however it is not limited only to the local law. 

67 

819 found to not meet international __standards __ and/or national labor law. Report 

standards 

Comment 

Mediating 

Institution 

Mediating 

Institution 

Oceania 

Oceania 

Report Reader 

STUDENT 

GROUP 

ASSIAGNMENT 

FOR 

MACQUARIE 

UNIVERSITY 

AUSTRALIA 

ACCG 260 

GROUP 

Report Reader 

STUDENT 

GROUP 

ASSIAGNMENT 

FOR 



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& laegal regulations 

67 

820-823 __Report actions taken to determine whether persons working for supplier... 


remunerated. 



Comment 


Unsure of what the difference is between these two disclosures. Does one refer to the individual and one refer to the supplier (as in 

the company or entity)? If so, it would help if that was made clearer. 

67 

821 working for suppliers are adequately __remunerated. __ Report actions taken to address 

remunerated. 

Comment 


Some country regulations do not allow organizations to request compensation information from its suppliers. 

67 

822-823 __Report actions taken to address situations where work undertaken withi... 



Comment 


Should be before 820 

67 

824-829 __Report actions taken to determine whether suppliers use sub-contractor... 



employer. 




Comment 


Mediating 

Institution 

Northern 

America 

MACQUARIE 

UNIVERSITY 

AUSTRALIA 

ACCG 260 

GROUP 

Consultant 



Academic 

Mediating 

Institution 

Northern 

America 

Consultant 



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It seems as if, for the sake of clarity and brevity that these two indicators could be combined into one that encompasses both 

"determined" and "addressed" 

67 


Report actions taken to determine whether work undertaken within the organization’s supply chain is performed at home and 

whether it is performed subject to a legally-recognized 

contract. 



Comment 


Unsure of the relevance of whether the work is performed at home or not. 

68 

865 processes, and the involvement of __local __ community/workers’ representatives’ in monitoring their 

local 

Comment 


Organisations should be encouraged to explain what is an appropriate 'local' context for them - and why have they chosen that in 

their specific context. This commment is applicable at all placed where 'local' is mentioned and hence should be a part of 

Management Approach. 

73 



Comment 


There's a whole section on screening for labor practices in the overall DMA for this section. Having two screening and assessment 

portions that are similar but different is confusing. 

73 

870 AND ASSESSMENT CORE G4 8 __Percentage of new suppliers and __ other business partners screened for 

Percentage of new suppliers and 

Comment 


Again, I trust we could set a threshold ? I woudn't even know how many new suppliers of office supplies at our different locations - 

but I might be able to evaluate for suppliers on which we spend significant amounts of money (a significant percentage of our 

purchasing budget) 

73 

880 identified through screening. Report the __percentage of new suppliers __ and other business partners where 

percentage of new suppliers 

Mediating 

Institution 

Northern 

America 

Consultant 


Mediating 

Institution 

Business 

Business 

Northern 

America 

Northern 

America 

Northern 

America 

Consultant 

Reporter 

Reporter 



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Comment 


As our spend is concentrated (91% of our sourceable spend is with fewer than 125 suppliers), we think it makes sense to "follow the 

money." Therefore, we recommend having as an option to report on the % of spend and not just the number of suppliers. 

73 




Comment 


Same comment as the same disclosure in the EN section - unsure why percentage of rejected suppliers is important. What would 

constitute improvement on this indicator YOY? 

73 



Comment 


As with environment - is every purchaser expected to do their own analysis of the same supplier ? I am to evaluate General Motors 

labour practices ? 

73 





Mediating 

Institution 

Business 

Mediating 

Institution 

Northern 

America 

Northern 

America 

Northern 

America 

Consultant 

Reporter 

Consultant 



Comment 


For clarity and brevity these two indicators should be combined and address both "number" and "percentage" 

74 

922 of people identified by: o __Gender __ o Membership of underrepresented social 

Gender 

Comment 


delelte 

Mediating 

Institution 

Oceania 

Report Reader 

STUDENT 

GROUP 

ASSIAGNMENT 

FOR 

MACQUARIE 

UNIVERSITY 

AUSTRALIA 



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77 


significant 

Comment 


As mentioned before, the cost to monitor this in the whole supply chain on a first moment might be impeditive for large 

organizations to report on this. 

78 


significant 

Comment 


I big load added to the reporter to have to report on every supplier. 

79 

978 ASPECT: SCREENING AND CORE HR2 __Percentage of new suppliers and other business partners screened __ for human rights 

performance, and 

Percentage of new suppliers and other business partners screened 

Comment 


I presume we could do a percentage not based on number (ie. one partner) but based on the scale of the relationship ? (i.e. we have 

screened partners representing 75% of our financial investments in partner companies ?) 

79 




Comment 


Same comment as same disclosure in EN and LA 

80 



and potential adverse human rights impacts 

Comment 


Same as for environment and labour - is each purchaser to assess every supplier (everyone who buys i-phones for employees is to 

evaluate Apple ?) 

ACCG 260 

GROUP 


Business 

Business 

Mediating 

Institution 

Business 

Northern 

America 

Northern 

America 

Northern 

America 

Northern 

America 

Reporter 

Reporter 

Consultant 

Reporter 



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80 



potential adverse human rights impacts, broken down by location of the supplier and other business 

partner. 

Mediating 

Institution 

Northern 

America 

Consultant 

Report the percentage of total existing suppliers and other business partners identified as having actual 

and potential adverse human rights impacts, broken down by location of the supplier and other business partner. 

Comment 



81 

1043 an organization). CORE HR 11 __Number of grievances about human rights impacts __ filed, addressed and resolved through 

Number of grievances about human rights impacts 

Comment 


This needs to be put in relation to something. A high number of grievances reflects a good grievance system. It is more interesting to 

see share of operations where a good grievance system is in place. 

81 

1053-1054 people identified by: o Gender __o Membership of underrepresented social groups o Other indicators of diversity, if 

applicable __ Of the identified grievances, report 

o Membership of underrepresented social groups o Other indicators of diversity, if applicable 

Comment 


This detailed reporting on grievance can be sensitive depending on the context. Underepresented social groups can be on ethnic, 

religious, social backgrounds etc. Companies can choose to provide comments - and not necessarily disclose in a graphic/tabular 

data intensive format. 

86 



Comment 


'Screening and Assessment' of supply chain can cover material aspects/topics identified and not necessarily cover all EN, HR, LA, SO 

indicators. These are complex issues and companies should be able to choose to report on their chosen context/scope and explain. 

86 

1098 other business partners screened for __society-related __ performance, and actions taken [Standard 


Comment 







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What is the definition of society-related performance? 

86 

1098-1099 other business partners screened for __society-related performance, __ and actions taken [Standard Disclosure] 


Comment 


This seems overly vague. What constitutes society-related performance? This is more than a "wording comment" because it affects 

the content of other proposed new indicators as well. 

86 

1110-1111 __Report the percentage of new suppliers or other business partners that... 

Report the percentage of new suppliers or other business partners that were not selected or contracted as a result of screening. 

Comment 


Same comment as same disclosure in EN, LA, HR 

86 



and potential adverse impacts on society assessed on 

Comment 


again, who identifies ? Do I evaluate Shell's impact on society because I buy fuel from them ? 

86 

1117-1118 business partners identified as having __actual and 

potential adverse impacts on society, __ broken down by the location 

actual and 

potential adverse impacts on society, 

Comment 


Overly vague terminology 

86 



potential adverse impacts on society, broken down by the location of the supplier and other business 

partner. 


impacts on society, broken down by the location of the supplier and other 

Mediating 

Institution 

Mediating 

Institution 

Business 

Mediating 

Institution 

Mediating 

Institution 

Northern 

America 

Northern 

America 

Northern 

America 

Northern 

America 

Northern 

America 

Consultant 

Consultant 

Reporter 

Consultant 

Consultant 



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Comment 



87 

1140 issues identified. CORE G4 14 __Number of grievances __ about society-related impacts filed, addressed, 

Number of grievances 

Comment 


It is not applicable to measure society related impactc resolved through formal grievance mechanisms. In most developing countries 

these sort of formal grievenace mechanisms are not in place. Therefore this number will be very low in developing country, which 

only indicates no formal grievance mechanisms. 

111 

1220 ASPECT: PROCUREMENT PRACTICES CORE EC6 __Spending on __ locally-owned suppliers broken down by 

Spending on 

Comment 


Total nr of spending needs to be related to something. An absolute number does not say anything about the stratege and is not 

comparable to anything. It cannot measure improvement in strategy, as it might only reflect total increase of business. 

111 


locally-owned 

Comment 


As a service company with a national footprint, "locally-owned" is difficult to define and on matters related to the purchase of 

software, it becomes even more challenging. Recommend that the question be reworded to report on forms of economic inclusion, 

including locally-owned, as "locally-owned" is a subset to the broader category of "economic inclusion," which we interpret as 

supplier diversity, and for which we do track our spend. 

111 

1224-1225 __Report the total monetary value of spending on locally-owned suppliers... 

Report the total monetary value of spending on locally-owned suppliers at significant locations of 

operation. 

Comment 


This would be hard to do for a multinational - depending on the definition of 'significant locations' 

111 

1249-1250 __The organization’s definition of ‘local’ may include, but it is ... 

The organization’s definition of ‘local’ may include, but it is not limited to, the community surrounding operations, a city, a region, 



Business 

Business 

Northern 

America 

Northern 

America 

Reporter 

Reporter 




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or country. 

Comment 


Good, however organisations be prompted to explain rationale beyond their definitions. 

113 


Report the percentage of total supplier expenditure spent on suppliers with which long-term agreements exist. 

Comment 


What is the purpose of this? We do not see the relevance between this and CSR reporting. 

113 

1282-1284 __This Indicator helps quantify the stability of an organization’s sup... 

This Indicator helps quantify the stability of an organization’s supplier base. Long-term relationships with suppliers enable an 

organization to work with their suppliers to improve their economic, environmental 

and social performance through, for example, capacity building. 

Comment 


This is saying that GRI is placing increased importance on long-term agreements - that they are considered better than having 

smaller short-term agreements. I do not see the CSR relevance in this. In FIs most suppliers are IT based or paper. I see this more 

important for large manufacturers. 

114 

1308-1309 __Report the percentage of total suppliers with which orders were placed... 



Comment 


Very hard to gather and make meaningful - I could ask all our accounts payable departments to identify what number of new 

supplier codes were set-up in the year versus total distinct suppliers paid, but that might include suppliers that for some reason 

changed in coding etc. - it would be very burdensome to evaluate every supplier relationship. 

114 

1312-1314 __A high turnover of suppliers may indicate that supplier selection or r... 

A high turnover of suppliers may indicate that supplier selection or relationship management are ineffective, undermining the 

organization’s ability to effect sustainability improvements. A 

Comment 


This is not true. In some communities suppliers could be run by small organizations. We have had some suppliers in some countries 

be microentreprenuers, whereby their capacity is only to sign short-term contracts, until they build the capacity to grow. Having 

many of these type of suppliers would be detrimental if GRI would consider this a high-turnover and a negative aspect. I understand 

Business 

Business 

Business 

Business 

Northern 

America 

Northern 

America 

Northern 

America 

Northern 

America 

Reporter 

Reporter 

Reporter 

Reporter 



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Relationship 

that we would need to describe the materiality and context, but this would take a considerable amount of work for a multinational 

in over 50 countries. 

115 

1338 taken to pay supplier invoices. __Report the percentage of total payments to suppliers that were made late. __ [Guidance] 

Relevance This Indicator identifies 


Comment 


Not sure many accounting systems track the due date of an invoice ? 

177 

1402 business partners screened for environmental __performance, __ and actions taken [Standard Disclosure] 

performance, 

Comment 


http://www.iasplus.com/en/publications/united-kingdom/industry-accounting-alerts/manufacturing-accounting-alert 

177 




Comment 


I suggest that shall be included only suppliers related to critical inputs 

177 




Comment 



177 




Comment 



177 

1412 business partner) Report issues identified __through __ screening. Report the percentage of 

Business 

Mediating 

Institution 

Northern 

America 

Latin America 

Reporter 

Reporter 


Report Reader 



Mediating 

Institution 

Latin America 

Reporter 



Page 1608 of 2491


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through 

Comment 


http://www.iasplus.com/en/publications/united-states/heads-up/2012/heads-up-2014-pcaob-approves-auditing-standard-oncommunications-with-audit-committees 

177 

1417 as a result of screening. __Report other actions taken to address the issues identified. __ [Guidance] Relevance This Indicator 

helps 


Comment 



177 


helps 


Comment 



177 


helps 


Comment 



177 

1427 for data collection Identify the __total number of new suppliers __ and other business partners that 

total number of new suppliers 

Comment 


Could there also be the option of expressing in terms of percentage of value of total procurement (rather than or in addition to 

number of suppliers) so that we could focus on larger relationships ? 

178 

1433- __Identify issues revealed through screening and actions taken to addres... 

Identify issues revealed through screening and actions taken to address these issues. Actions may 

include, but are not limited to, setting performance expectations or not selecting or contracting suppliers and other business 

partners. 


Report Reader 



Business 

Northern 

America 

Reporter 


Academic 



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Definitions 

SCREENING 

A formal or documented process that applies a set of performance criteria as one of the factors in 

determining whether to proceed with a relationship with a supplier or other business partner. 

SUPPLIER 

See the Glossary for the definition of supplier. 

Documentation 

Potential sources of information include the organization’s procurement, purchasing and legal 

departments. 

References 

None. 

1447 

Comment 


Should be incorporated into Disclosure on Management 

179 


ASPECT: 

Comment 


Should be incorporated into Management Disclosure on Supply Chain 

238 



Academic 


Academic 

CORE HR2 Percentage of new supplier... 





Page 1610 of 2491


Relationship 

Comment 


Should be incorporated into Management Disclosure 

238 


Report the percentage of new suppliers and other business partners screened for human rights 


Comment 


Comments on Global Reporting Initiative Proposed draft G4 Guidelines. 

I would like to offer one comment on the Human Rights aspect “Investment” at “CORE HR1 Percentage and total number of 

significant investment agreements and contracts that include human rights clauses or that have undergone human rights 

screening”. 

One of the key challenges in the area of Human Rights reporting is the lack of quantitative data. This was noted in the GRI sponsored 

report “Reporting on Human Rights” (Global Reporting Initiative, 2009). While environmental and economic results are reported 

quantitatively, the Human Rights area contained little quantitative data. 

The Core HR1 Aspect is measuring the number of contracts or agreements that include human rights clauses. This is a helpful 

measure in that the reader can look for changes from year to year. However, it does not provide an evaluation of the extent to 

which the organization is working with suppliers that are conscious of human rights. A more meaningful metric would be the 

percentage of purchases that are made through suppliers that are under an agreement with a human rights clause. By computing 

the percentage of dollar purchases rather than only the number of agreements, it provides a more meaningful assessment of the 

extent to which the entity’s operations are addressing this issue. 

This data should be available through and entities purchasing data. Companies regularly track the volume of purchases that are 

made with vendors for internal management processes. In addition, companies are attempting to compile more information on 

their supply chain activities. 

Submitted by, 

Robert A. Rebman, CPA MBA 

Instructor, Benedictine University, Lisle, IL USA 

238 

1846 Screening for human rights performance __may cover, __ but is not limited to: 

may cover, 

Comment 


"should at least cover some of the following" 

Otherwise the screening might exclude all those criteria and yet be considered a HR screening 

242 

1869 CORE G4 11 Percentage of __existing suppliers __ and other business partners identified 

existing suppliers 

Mediating 

Institution 

Mediating 

Institution 

Northern 

America 

Europe 

Report Reader 

academic 

research 

Consultant 

Report Reader 




Page 1611 of 2491


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Comment 


Need more clearity on "existing suppliers". The new defintion applies all all tiers of suppliers, so how do we set a %? Should all 

suppliers in all tiers have been individually screened for HR? We suggest 1:st and 2:nd tier, to make this approachable. 

268 



Comment 


Repetition to HR 1-7 AND TO G4 11 G4 8 TO 10 

314 

2683 another organization. In GRI’s Framework, __the term ‘supplier’ includes but is not limited to:__ 

the term ‘supplier’ includes but is not limited to: 

Comment 


re-order bullets, considering eg logical flow of a supply & value chain from upstream to downstream, and/or organisational vs 

individual suppliers. 

315 




Replace 


by "A network of organizations (e.g. manufacturers, wholesalers, distributors and retailers) involved in production, delivery and sale 

of a product to consumer." Context- Reference WRI/WBCSD GHG protocol supplenet (2011) has defined this and is widely accepted 

and used. 

315 




Comment 


Omit reference to value chain in this definition as it confused the definition of supply chain. There is no reason to mention value 

chain in this definition as value chain is defined separately and makes no mention specifically of supply chain in its definition. This 

change will make it much easier to understand the two different definitions especially for first time reporters who when reading the 

definition of supply chain in its current format are confronted with the words value chain in the definition of supply chain. 


Academic 

Mediating 

Institution 

Europe 

Consultant 

Report Reader 


Assurance 

Provider 

Report Reader 

Assurer 


std., ISO-14064 


ISO-14001 

Lead auditor 


Consultant 

Institution 



Page 1612 of 2491

Global Reporting Initiative 

PO Box 10039 

1001 EA Amsterdam 

Netherlands 

Tel: +31 (0)20 531 00 00 

Fax: +31 (0)20 531 00 31 

Further information on the Second G4 Public 

Comment Period may be obtained from: 

G4@globalreporting.org 

Further information on GRI and the Sustainability 

Reporting Guidelines may be obtained from: 

www.globalreporting.org 

info@globalreporting.org 

©Global Reporting Initiative. 

All rights reserved. 

GRI is a Collaborating Centre of the United Nations 

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